Purpose

This policy affirms our commitment to contribute to ending all forms of modern slavery and outlines our approach to reducing the risk of modern slavery practices within our supply chains and operations.

It is consistent with our code of ethics, that expects a culture of high ethical standards, including compliance with applicable laws, contractual and other obligations. It is also consistent with the

This Policy also supports the intent of international conventions, treaties and protocols relevant to combatting modern slavery and the Modern Slavery Act (Cth) 2018.

Scope

This policy applies to all Biotao employees, and contractors (including temporary contractors) of Biotao wherever located. In certain circumstances the obligations set out in this Policy may extend to employee and contractors connected persons.

Definitions

Modern Slavery Act 2018 (Cth)

Modern Slavery Act 2018 (Cth) being the Commonwealth legislation (the Act) enacted by the Parliament of Australia on 29 November 2018 (and may be amended from time to time).

Modern slavery

Modern slavery for the purposes of this policy is defined as including eight types of serious exploitation and outlined in sections below.

Operations

Operations is defined as activity undertaken by all Biotao Business Units.

Risks of modern slavery practices

Risks of modern slavery practices means the potential for Australian Red Cross to cause, contribute to, or be directly linked to modern slavery through its supply chains and operations.

Staff

Staff includes managers and supervisors; full-time, part-time or casual, temporary or permanent staff; job candidates; student placements, apprentices, contractors, sub-contractors and volunteers.

Suppliers

Suppliers is defined as any organisation or person who provides us with goods or services, including their subcontractors, agents, related entities and consultants.

Supply chains

Supply chains is defined as the products and services (including labour) that contribute to Biotao’s own products and services. This includes products and services sourced in Australia or overseas and extends beyond direct suppliers.

Modern Slavery

Modern slavery is defined by the Modern Slavery Act (Cth) 20184 to include eight types of serious exploitation and which can be understood as:

  • trafficking in persons, which is the recruitment, harbouring and movement of a person for the purposes of exploitation through modern slavery. Exploitation also includes the prostitution of others or other forms of sexual exploitation, forced labour or services, slavery or practices similar to slavery, servitude or the removal of organs;
  • slavery, which is where the offender exercises powers of ownership over the victim;
  • servitude which is where the victim’s personal freedom is significantly restricted and they are not free to stop working or leave their place of work;
  • forced labour, which is where the victim is either not free to stop working or not free to leave their place of work;
  • forced marriage, which is where coercion, threats or deception are used to make a victim marry or where the victim does not understand or is incapable of understanding the nature and effect of the marriage ceremony;
  • debt bondage, which is where the victim’s services are pledged as security for a debt and the debt is manifestly excessive or the victim’s services are not applied to liquidate the debt, or the length and nature of the services are not limited and defined;
  • the worst forms of child labour, which involves situations where children are: exploited through slavery or similar practices, including for sexual exploitation; or engaged in hazardous work which may harm their health or safety, or used to produce or traffic drugs; and
  • deceptive recruiting for labour or services which is where the victim is deceived about whether they will be exploited through a type of modern slavery.

It can also extend to:

  • entering into a commercial transaction involving a slave;
  • exercising control or direction over, or providing finance for, any commercial transaction involving a slave or act of slave trading;
  • conducting a business involving servitude or forced labour (including exercising control over the business or providing finance to it);

Limiting the risk of modern slavery

Biotao will work proactively to reduce modern slavery within our supply chains and operations and we expect all organisations we engage with to do the same.

Supply Chain

Supplier Code of Conduct
We expect all existing and new Suppliers to comply with the principles set out in our Supplier Code of Conduct. Fundamental to the Supplier Code of Conduct is an expectation that all Suppliers operate in full compliance with the laws and regulations in the jurisdiction where the goods are sourced, procured or services are performed.

Suppliers must use best endeavours to ensure that there is no modern slavery in their supply chains and operations. In the event Suppliers identify any occurrence of, or material risk of modern slavery in their supply chains or operations they are to take practical and effective steps to address that occurrence or risk. Suppliers must notify Biotao as soon as practical of any occurrence of, or material risk of modern slavery they have identified and notify relevant authorities where appropriate.

Biotao's Contractual terms
Our contractual terms reflect Supplier obligations outlined in the Supplier Code of Conduct, including compliance with Australian modern slavery laws and those foreign modern slavery laws that apply in the location(s) in which they operate.

Supply chain mapping and risk assessment
We encourage our suppliers to complete a Corporate Social Responsibility questionnaire which contains questions relevant to modern slavery.

Answers provide us with a greater understanding of the risk of modern slavery within a supplier’s supply chains or operations and enable us to work with a supplier to reduce the risks identified. We will actively and progressively improve our understanding and oversight of all tiers of our supply chains.

Operations

Modern Slavery Policy
Biotao maintains a Modern Slavery Policy (this Policy) outlining our approach to reducing the risk of modern slavery practices within our supply chains and operations. The Policy provides guidance on the steps Biotao takes to work with suppliers to reduce risks and the range of supports available for when Biotao staff becomes aware that someone is at risk of or affected by modern slavery practices.

Incorporating modern slavery into other policies
When existing policies undergo review or new polices are under development, Biotao are required to identify existing modern slavery commitments that can be enhanced, or where modern slavery protections can be incorporated.

Human Resources
We are committed to ensuring the health, safety and wellbeing of our workforce and we maintain a suite of policies that are informed by and compliant with Australian workplace and  occupational health and safety law. We ensure that our volunteers are engaged on a truly voluntary and non-exploitative basis.