Modern Slavery Policy

1. Purpose and Scope

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.

The Policy applies to our employees, directors, officers, seconded workers, interns, agents, contractors, external consultants, third-party representatives, suppliers and business partners (You).

2. What is Modern Slavery?

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.

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 the reporting mechanisms set out in section 11 of this Policy.

3. AirTrunk’s Modern Slavery Policy

AirTrunk is committed to acting ethically and with integrity in all our business relationships and have 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 supply chains and operations to the extent possible, and to ensure that any instances with modern slavery reported to AirTrunk are investigated and addressed appropriately.

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, distributors and partners to adopt similarly high standards.

4. Scope

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control.

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.

5. Roles and Responsibilities

The AirTrunk Board of Directors has overall responsibility for ensuring this Policy complies with AirTrunk’s legal and ethical obligations and that all management and employees of AirTrunk comply with the Policy.

The AirTrunk Chief Legal Officer has primary day-to-day responsibility for implementing this Policy and will ensure that appropriate training is provided to AirTrunk employees.

All employees are responsible for modern slavery risk management in their respective areas of the business.

Management at all levels will:

listen and be approachable to others within AirTrunk’s business.
respond appropriately if they are told something that might indicate an exploitative situation.
remain alert to indicators of modern slavery.
use their experience and professional judgment to gauge situations; and
ensure that those reporting to them understand and comply with this Policy.

You are also invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Chief Legal Officer.

6. AirTrunk Modern Slavery Statement

Australian modern slavery legislation requires that 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. The specific AirTrunk entities required to report each year will therefore depend upon the consolidated revenue and business activities in Australia. The Modern Slavery Statement of those reporting AirTrunk entities must outline:

AirTrunk’s structure, operations and supply chains.
the risks that AirTrunk may cause, contribute or be directly linked to modern slavery practices in its operations and supply chains.
the actions AirTrunk have taken to address these risks; and
an assessment of the effectiveness of the actions taken.

The Modern Slavery Statement must be approved by the principal governing body of the reporting AirTrunk entity (for instance, the board of directors) and submitted to the Australian Border Force within six months of AirTrunk’s financial year end.

The governing body of the AirTrunk entity with control of any other AirTrunk entity also providing the modern slavery statement will approve the statement on behalf of all AirTrunk entities reporting under to the Modern Slavery Statement (i.e., if it is a joint modern slavery statement).

Further detail on Australia’s modern slavery legislation can be found at: www.homeaffairs.gov.au/criminal-justice/pages/modern-slavery.aspx

7. Communication of the Policy

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.

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.

8. Supplier due diligence and contract terms

Before engaging a supplier, you must always conduct appropriate due diligence. This includes establishing how that supplier identifies, prevents, mitigates and addresses actual and potential adverse human rights impacts in their operations and supply chains, including modern slavery.

All new AirTrunk supplier contracts must include the AirTrunk modern slavery precedent contractual provision, or a clause with similar effect.

9. Remediation

If AirTrunk identifies that it has caused or contributed to an instance of modern slavery, AirTrunk will adopt measures to try to ‘make good’ all adverse impacts. In addition, where AirTrunk hasn’t caused or contributed to modern slavery but is indirectly linked to the it by virtue of a business relationship we will endeavour to use any leverage to work with the entity that caused the impact, to prevent or mitigate the harm and its recurrence. If this is unsuccessful, we will always consider ending the business relationship.

10. Compliance with the Policy

You must ensure that you read, understand and comply with this Policy.

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.

11. Reporting Mechanisms

You are encouraged to raise concerns you may have about any issue or suspicion of slavery or human trafficking in any parts of our business or supply chains at the earliest possible stage.

If you have these concerns relating or are otherwise unsure as to whether a particular act or treatment of workers or working conditions in AirTrunk’s supply chains constitutes any of the various forms of modern slavery, you must raise this confidentially with your supervisor or the AirTrunk Chief Legal Officer. If you would prefer to raise these concerns on an anonymous basis, AirTrunk’s Whistle-blower Policy may also be followed. Once your concern has been raised, the Chief Legal Officer will assess your concern and take further steps as required to appropriately investigate and address the situation, whilst taking care to preserve the anonymity and privacy of affected individuals.

AirTrunk aims to encourage openness and will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting under this Policy. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the AirTrunk Chief Legal Officer immediately. If the matter is not remedied, and you are an employee of AirTrunk, you should raise it formally using our Appropriate Workplace Behaviour Policy and Complaints Procedure, which can be found on SharePoint at the “Corporate Policies” section.

12. Breaches of this Policy

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.

We may also terminate our relationship with 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.

13. Policy Review

This Policy will be reviewed at least every two years and updated as required in line with recommendations arising from further modern slavery risk assessments which will be conducted by AirTrunk on a regular basis.

14. Accessing the Policy

This Policy can be viewed on the AirTrunk Intranet in the “Company Policies” section. A copy of this Policy will also be made available on AirTrunk’s website.