Modern Slavery Policy

As a team member, you are responsible for:

• Familiarising yourself with this Policy; and
• Managing any risk or instance of modern slavery which is encountered in accordance with this policy.

If you are part of the leadership team, you will also need to ensure you:

• Oversee the implementation and adherence to this Policy; and
• Provide advice to team members in accordance with this Policy.

This policy applies to:

• All current team members; and
• Clients of Boyce and their enterprises; and
• All of Boyce’s suppliers of goods and services (“Suppliers”), including contractors and employees of companies we engage for outsourced support.

As part of induction, all team members and suppliers must read and understand this Policy, which is available on BKB.

Boyce expects all team members, clients and suppliers to work together to assist us to give effect to the principles set out in this Policy.

‘Modern Slavery’ describes situations where offenders use coercion, threats or deception to exploit victims and undermine or deprive them of their freedom.

‘Modern slavery’ is defined by the Modern Slavery Act (Cth) 2018 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.

Modern slavery may involve the exploitation of debt and the use of violence and/or threats of violence (psychological or physical), isolation, deprivation of liberty and the withholding of critical identification documents such as passports.

In this Policy, we use the term ‘modern slavery’ to encompass all of the practices to which the Modern Slavery Act refers.

Modern slavery occurs in a wide range of industries and businesses across the world, including in Australia. Certain groups within the community, such as migrants, women and children, are particularly at risk of modern slavery.

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

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

Boyce is committed to ensuring:

• Its operations and supply chain do not cause, involve or contribute to modern slavery; and
• Its suppliers and any others organisation we engage with respect and share Boyce’s commitment to minimising the risk of modern slavery.

1. Supply chain

Boyce expects all existing and new suppliers to uphold high standards of human rights and 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 (which includes completing risk assessment, audits, due diligence, having reporting and grievances processes in place, etc.).

In the event Boyce’s 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 Boyce as soon as practicable of any occurrence of, or material risk of modern slavery they have identified and notify relevant authorities where appropriate. Suppliers must also notify Boyce of the corrective action plan put in place to remediate identified modern slavery and keep Boyce informed of the effectiveness of these measures.

2. Operations

Modern Slavery Policy

Boyce maintains a Modern Slavery Policy (this Policy) outlining our approach to reduce the risk of modern slavery practices within our operations and supply chain. This Policy provides guidance on the steps Boyce takes to work with suppliers to reduce risks and the range of support available for when a Boyce team member or supplier becomes aware that someone is at risk of or affected by modern slavery practices.

Human Resources

Boyce is committed to ensuring the health, safety and wellbeing of our team members and we maintain a suite of policies that are informed by and compliant with Australian workplace and occupational health and safety law. These policies are regularly reviewed by Boyce.

Boyce also conducts regular audits of wages, salaries and employment conditions of our team members to ensure compliance with Australian workplace laws.

Communications and Training

Boyce’s team members and suppliers are provided communication and training opportunities to enhance their understanding of the causes and humanitarian impact of modern slavery, what is required to identify, assess and address modern slavery, their responsibilities under this Policy and Boyce’s approach to limiting the risk of modern slavery within its operations and supply chain.

Promoting awareness of modern slavery enables Boyce’s team members and suppliers to identify modern slavery risks more easily so that Boyce can respond appropriately to those risks.

The often hidden nature of modern slavery practices means it can be difficult to identify and can be difficult for people to report.

However, Boyce encourages its team members, suppliers and others to feel empowered and safe to speak up and raise their concerns with our Operations team [email protected] if they become aware of any action or decision which is inconsistent with this Policy, or a suspected instance of modern slavery within Boyce or its supply chain.

Reports of concerns about modern slavery can be made anonymously and are responded to in accordance with whistleblower protection provisions as outlined in the Corporations Act. The reporting team member or supplier will be protected from retaliation and information will be kept confidential.

Any breach of this Policy, as varied from time to time, will be taken seriously and conduct in contravention of this policy may be regarded as misconduct, leading to disciplinary action up to and including termination of employment. An individual may also be exposed to criminal or civil liability for breaching the law.