Modern Slavery Policy

1. Purpose

  1. AirTrunk is committed to acting ethically and with integrity in all our business relationships and has a zero-tolerance approach to modern slavery. To this end, we are committed to implementing and enforcing effective systems and controls to minimise the risks of modern slavery occurring in our operations and supply chains to the extent possible, and to ensure that any instances of modern slavery reported to AirTrunk are investigated and addressed appropriately.
  2. We are also committed to transparency in our own business and in our supply chains, consistent with our disclosure obligations under modern slavery legislation. We expect our contractors, suppliers, agents and partners to adopt similarly high standards.
  3. The AirTrunk Modern Slavery Policy (Policy) sets out the principles, policies and procedures in relation to modern slavery and modern slavery regulatory requirements which AirTrunk (or “our” or “we”) adheres to as a business.

2. Who does this Policy apply to?

  1. This Policy applies to:
    1. all directors, officers, employees and any other person whose work is supervised by AirTrunk as though that person were an AirTrunk employee (AirTrunk Personnel);
    2. all AirTrunk operations, including all legal entities and business area units across the jurisdictions in which AirTrunk operates; and
    3. any other person or entity to the extent that they act on behalf of AirTrunk, including consultants, contractors, suppliers, agents or intermediaries.

3. What is Modern Slavery?

  1. The term modern slavery describes situations where coercion, threats or deception are used to exploit victims and undermine their freedom. There is no globally agreed definition of “modern slavery”, but the term describes various practices that seriously exploit people for personal or commercial gain including:

    • Human trafficking: exploitation of people through forced prostitution, labour, marriage, criminal activities or organ removal. Often threats of violence or coercion are used to harbour or recruit victims of human trafficking.
    • Slavery: where someone exercises powers attaching to the right of ownership over another person. This includes the power to make the victim an object of purchase.
    • Servitude: where a person provides labour or services and, because of the use of coercion, threat or deception, that person does not consider themselves free to cease providing the labour or services or to leave the area where they provide that labour or services, and they are significantly deprived of personal freedom.
    • Forced labour: work performed, or services provided against someone’s will and/or under threat of punishment to themselves or their family.
    • Debt bondage: work performed, or services provided in order to pay off a debt with no control over how the debt is paid off, or employment conditions.
    • Forced marriage: marriage against someone’s will and with no option to leave that marriage. Often will include unpaid domestic labour as part of the force marriage.
    • Child labour: where a child under the age of 18 years is exploited for labour. Child labour is in relation to work that deprives children of their childhood, their dignity and is mentally, physically or morally dangerous to children.
    • The Appendix to this Policy gives examples of red flags to look out for in considering whether modern slavery might be occurring.

4. Roles and Responsibilities

  1. All AirTrunk Personnel are responsible for modern slavery risk management in their respective areas of the business and to ensure that suppliers share our values and commitments. You are required to avoid any activity that might lead to, or suggest, a breach of this Policy. As such you must ensure that you read, understand and comply with this Policy.
  2. AirTrunk Personnel at all levels must:
    1. listen and be approachable to others within AirTrunk’s business;
    2. respond appropriately if they are told something that might indicate an exploitative situation;
    3. remain alert to indicators of modern slavery;
    4. use their experience and professional judgment to gauge situations;
    5. report modern slavery concerns in accordance with the reporting mechanisms in section 9; and
    6. ensure that those reporting to them understand and comply with this Policy.
  3. The AirTrunk Associate Vice President, Sustainability has primary day-to-day responsibility for maintaining this Policy, monitoring its use by AirTrunk Personnel, ensuring its effectiveness is regularly reviewed and ensuring that appropriate training is provided to AirTrunk employees.
  4. Various teams within AirTrunk support the Associate Vice President – Sustainability in the implementation of this policy, including:
    • Supply Chain & Procurement team: implementation and executesion AirTrunk’s supply chain risk management programs (see section 6).including to ensure modern slavery concerns are addressed as part of this programme; supplier monitoring (including though audits, declarations and risk assessments); engages with vendors on remediation in actual or suspected instances of modern slavery
    • Legal team: reviews regulatory change concerning modern slavery across our jurisdictions and ensures this Policy and annual modern slavery statements meet legal and regulatory requirements, ensuresinclusion of contractual obligations on our vendors to identify, and reviews and advises of reported instances of modern slavery for further escalation as needed;
    • Risk & Resilience: facilitates identification of modern slavery risk and remediation of reported modern slavery and oversees implementation of relevant actions as part of AirTrunk’s enterprise risk profile.
    • Sustainability: aligns long term sustainability goals with core governance principles including human rights and modern slavery; reviews supply chain ESG credentials and highlight any areas for improvement.
  5. The AirTrunk Board of Directors has overall responsibility for ensuring this Policy complies with AirTrunk’s legal and ethical obligations.

5. AirTrunk Modern Slavery Statement

  1. This Policy applies to all AirTrunk operations, including all legal entities and business area units across the jurisdictions in which AirTrunk operates.
  2. In Australia, specific modern slavery legislation applies under which reporting entities publish a statement each financial year (a Modern Slavery Statement). A reporting entity is an entity which has a consolidated revenue of at least A$100 million in the relevant financial year and which is an Australian entity or carries on business in Australia. Whilst only certain Australian entities within the AirTrunk need to report, AirTrunk reports on a group-wide basis voluntarily,. Our Modern Slavery Statement is published annually with the Department of Home Affairs’ online modern slavery statements register and is also available on the AirTrunk website.

6. Supplier due diligence and contract terms

  1. AirTrunk’s Supply Chain Risk Management (SCRM) programs enable proactive identification, assessment, and management of key supply chain risks, ensure supplier qualification against ESG criteria and other risk areas, and support continuous monitoring. One of the key SCRM programs is Know Your Supplier (KYS). Before engaging a supplier, you must follow all mandatory screening requirements under AirTrunk’s KYS program (further information on these can be found on AirTrunk’s intranet here: Supply Chain & Procurement Hub – Home). Certain categories of suppliers are required to undergo enhanced supplier due diligence in accordance with the KYS process.
  2. The enhanced supplier onboarding aims to gather information about how a supplier identifies, prevents, mitigates and addresses actual and potential adverse human rights impacts in its own operations and supply chains, including with respect to modern slavery.
  3. Suppliers are continually screened and otherwise monitored periodically under KYS. Certain strategic suppliers are subject to further robust governance and oversight from AirTrunk (further information can be found on AirTrunk’s intranet here: Supply Chain & Procurement Hub – Home).
  4. All new AirTrunk supplier contracts must include the AirTrunk modern slavery precedent contractual provisions, or clauses with similar effect. AirTrunk modern slavery precedent contractual provisions serve to impose contractual requirements on relevant vendors to maintain effective policies and procedures to identify and address its exposure to modern slavery risk, maintain records detailing source and supply chain for services or goods provided and to notify AirTrunk in case of any actual or suspected instances of modern slavery.

7. Remediation

  1. 6.1 If AirTrunk identifies that it has caused or contributed to an instance of modern slavery, AirTrunk will adopt measures to appropriately address all adverse impacts. In addition, where AirTrunk hasn’t caused or contributed to modern slavery but is indirectly linked to it by virtue of a business relationship we will endeavour to work with the entity that caused the impact, to prevent or mitigate the harm and its recurrence. AirTrunk may elect to terminate its relationship with any supplier who breaches modern slavery laws, this Policy or the Supplier Code of Conduct.

8. Communication of the Policy

  1. AirTrunk will provide training to all employees on this Policy. This will include training on how to identify modern slavery practices and the particular parts of AirTrunk’s business and supply chains which are subject to a greater risk of modern slavery practices. This training will also form part of the induction process for all individuals who work for AirTrunk, whether as an employee or contractor.
  2. AirTrunk’s zero-tolerance approach to modern slavery in its business and supply chains must be communicated to all suppliers, contractors and business partners at the outset of any business relationship with AirTrunk and reinforced as appropriate thereafter.

9. Raising Concern

  1. If you become aware of any information that gives you concerns about modern slavery related to AirTrunk, you must report your concern to Associate Vice President, Sustainability as soon as possible.
  2. In raising your concern, you may wish to follow the whistleblowing process applicable to your circumstances (see AirTrunk’s website for more details on AirTrunk’s Whistleblowing Policies). AirTrunk’s online whistleblowing platform (accessible via: https://www.whistleblowingservice.com.au/airtrunk/) allows you to raise concerns anonymously if desired.
  3. AirTrunk is committed to protecting individuals who raise concerns regarding breaching of the Policy from detrimental treatment. Our Whistleblowing Policies describe how to raise concerns and those protections. Such protections are an essential element of creating an environment in which all AirTrunk Personnel and third parties are comfortable reporting any improper conduct internally. This protection is in addition to any rights and protections legally conferred on a person making such a report.

10. Compliance with this Policy

  1. You must ensure that you read, understand and comply with this Policy.
  2. The prevention, detection and reporting of modern slavery in any part of AirTrunk’s business or supply chains is the responsibility of all those working for AirTrunk. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
  3. Breaches of this Policy by employees will be dealt with very seriously. For example, instances of encouraging modern slavery or failing to report modern slavery may result in disciplinary action up to and including dismissal.
  4. We may also terminate our relationship with suppliers or other individuals and organisations who work with us or on our behalf if we suspect that they have breached this Policy, their contractual commitments to AirTrunk in relation to modern slavery or any of their legislative obligations.

11. For further information

  1. If you have any questions about this Policy, please contact Associate Vice President Sustainability.

12. Changes to this Policy

  1. This Policy is owned by Associate Vice President – Sustainability . It is subject to review and update from time to time. Any changes to this Policy will be communicated to you.

13. Related Policies

  1. Our commitment to responsible supply chain is further outlined and implemented through AirTrunk’s suite of related policies, including the following key policies:
    • Supplier Code of Conduct.
    • AirTrunk Code of Ethics and Business Conduct
    • Human Rights Policy Statement.
    • Whistleblowing Policies.

Appendix

While modern slavery is more prevalent in certain countries and across certain industries, it can occur in every country and industry.

It is important to understand that there is no typical victim and some victims do not understand they have been exploited and are entitled to help and support. However, the following key signs could indicate that someone may be a slavery or trafficking victim, namely, the person:

  • is not in possession of their own passport, identification or travel documents;
  • is acting as though they are being instructed or coached by someone else;
  • allows others to speak for them when spoken to directly;
  • is dropped off and collected from work;
  • is withdrawn or they appear frightened;
  • does not seem to be able to contact friends or family freely; or
  • has limited social interaction or contact with people outside their immediate environment.

This list is not definitive nor exhaustive. It contains examples only.

Remember, a person may display a number of the trafficking indicators set out above, but they may not necessarily be a victim of slavery or trafficking. Often you will build up a picture of the person’s circumstances which may indicate something is not quite right. If you have a suspicion, please raise your concerns in accordance with this Policy.