Modern Slavery Policy

Modern Slavery Policy
POL-OG-08

PURPOSE

Oceania Glass Pty Ltd is committed to limiting the risk of modern slavery occurring within its own business, infiltrating its supply chains or through any other business relationships.  As a trusted Australian organisation, we will carry on business honestly and fairly, acting only in ways that reflect well on Oceania Glass in strict compliance with all laws and regulations including the Modern Slavery Act.

Caring for people is a core value of Oceania Glass and this policy is designed to provide guidance on the prevention, mitigation, and remediation of modern slavery within our business practices.  Oceania Glass is committed to the protection of human rights in our operations, supply chains & within our community both domestically & internationally.  Tackling modern slavery requires colleagues to play a part and remain vigilant to the risk in all aspects of the Oceania Glass business and business relationships.

 

SCOPE

This Policy applies to all persons working for or on behalf of Oceania Glass in any capacity, including employees, directors, officers, agency workers, contractors, consultants and any other third-party representative. Oceania Glass expects all who have, or seek to have, a business relationship with the Company to familiarise themselves with this policy and to act in a way that is consistent with its value.  The Company will only do business with organisations who fully comply with this policy, or those who are taking verifiable steps towards compliance.

WHAT IS MODERN SLAVERY?

All forms of modern slavery have in common the deprivation of a person’s liberty by another in order to exploit them for commercial or personal gain and amount to a violation of an individual’s fundamental human rights.  Modern Slavery can take many forms; it is a complex and multi-faceted problem.  Modern Slavery can include but is not limited to:

  • Slavery: where ownership is exercised over an individual.
  • Servitude: involves the obligation to provide service imposed by coercion.
  • Forced and compulsory labour: all work or service, not voluntarily performed, which is obtained from an individual under the threat of force or penalty.
  • Human trafficking: involves arranging or facilitating the travel of another with a view to exploiting them.
  • Child labour: involves the employment of children that is exploitative or is likely to be hazardous to or interfere with a child’s education, health (including mental health), physical wellbeing or social development.
RESPONSIBILITIES

The Senior Leadership Team has overall responsibly for this Policy and in ensuring that the Company complies with all its legal and ethical obligations.

The Chief Executive Officer will have the primary day-to-day responsibility for the implementation of this Policy, monitoring its use and ensuring that the appropriate processes and control systems are in place, and amended as appropriate, to ensure it can operate effectively.

Managers are responsible for ensuring that their direct reports are complying with the provisions of this policy in the day-to-day activities associated with their job function.

PROCEDURES & REQUIREMENTS

Oceania Glass takes the following steps to underpin our commitments laid out in this policy:

  • Conduct risk assessments to determine which parts of the business and which supply chains are most at risk from modern slavery so efforts can be focused on the areas that are most ‘at risk’.
  • Where appropriate, as informed by the risk assessment, Oceania Glass will engage directly with new suppliers in respect to this policy to gain a proper understanding of the measures they have in place to ensure that modern slavery is not occurring within their own business.
  • Contractual documentation shall incorporate specific prohibition against slavery nor servitude, the use of forced, compulsory or trafficked labour, and the use of child labour in line with this policy.
  • Make provisions for our contracted suppliers to hold their own suppliers to the same standards. We also reserve the right to terminate any contractual arrangement if there is a breach of this policy.
  • Perform periodic evaluations to ensure Oceania Glass Senior Leadership Team, Departments, Contractors & Suppliers are complying with this policy and all relevant legislation in their area of operation.
  • Where modern slavery cases or suspected cases arise, Oceania Glass will endeavour to engage collaboratively with suppliers to identify and implement measures to protect the victims and contribute to the future prevention of more modern slavery cases.
TRAINING & AWARENESS

The Senior Leadership Team will ensure that relevant colleagues receive adequate training on this policy and any supporting processes applicable to their role.  Training shall be provided initially during the induction process.  Refresher training shall be provided periodically in accordance with the individual’s defined training requirements. 

Additional refresher training may also be required if any non-compliance to the requirements of this policy is identified.

BREACHES OF THIS POLICY

All suspected or identified breaches of this policy will be thoroughly investigated & appropriate remedial action shall be taken.  Breaches in this policy by an employee of the Company may lead to disciplinary action being taken up to and including termination of employment.  Breaches in this policy or failure to take appropriate action by a supplier may lead to Oceania Glass discontinuing its relationship with that supplier. 

REVIEW

This Modern Slavery Policy will be reviewed by the executives on a regular basis to ensure it remains consistent with all relevant legislative requirements, as well as our core values & potential changes in our operational requirements.

APPROVAL

Corne Kritzinger – Chief Executive Officer – July 2024