Modern Slavery Policy

1. Overview

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. In accordance with the Australian Modern Slavery Act 2018, this statement outlines the steps that Qlicksmart Pty Ltd and Smartstream Pty Ltd have taken, and are continuing to take, to assess and reduce the risks of modern slavery within our businesses, our supply chain, and our plans for review and improvement as part of our zero tolerance approach to modern slavery. We recognise that we have a responsibility under the Modern Slavery Act to take a strong approach to reject any forms of modern slavery and human trafficking. We are committed to promoting ethical business practices and policies limit the risk of modern slavery occurring in our business and in our approach to tackling modern slavery throughout our supply chain.

 

2. Definitions

Criminal Code means the Criminal Code Act 1995 (Cth).

Company means both Qlicksmart Pty Ltd (ABN 37 033 096 995) and Smartstream Pty Ltd (ABN 31 104 544 158)

Modern Slavery Legislation means the Modern Slavery Act 2018 (Cth) (‘the Act’) and all future State and Territory modern slavery legislation (as amended from time to time).

Modern slavery (as defined in Divisions 270 and 271 of the Criminal Code 1995 (Cth) (Modern Slavery) is a crime and a violation of fundamental human rights. It takes various forms, such as:

slavery: one person treats another as though he or she owns that person and that person is deprived of his or her freedom;

servitude: a person is coerced to provide services, is forced to live on another person’s property and cannot change his or her condition;

forced labour: a person is forced to involuntarily work or to provide a service without remuneration under the menace of a penalty;

trafficking in persons (including trafficking of orphanage children): a person arranges or facilitates the travel of another person to be exploited, without that person’s knowledge or consent. This can be even where the person consents to the travel as they may have been deceived or unduly influenced; and

forced marriage: a person enters into a marriage without freely and fully consenting, because he or she was coerced, threatened or deceived or otherwise incapable of understanding the nature and effect of the marriage ceremony.

 

In addition, the definition of “modern slavery” in the Modern Slavery Act 2018 (Cth) (Modern Slavery Act) includes:

child labour: children below 12 years of age undertaking at least one hour of economic activity or 28 hours of domestic work or children aged between 12 and 14 years of age undertaking at least 14 hours of economic activity or 42 hours of domestic work and economic activity combined;

debt bondage: a person’s pledge of labour or services as security for the repayment of a debt or other obligation, but there is no hope of actually repaying the debt. The services required to repay the debt, or the time in which to repay the debt, may be undefined; and

other slavery-like practices.

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

Supply Chains is defined as the products and services (including labour), and the providers of those products and services, that contribute to the Company’s own products and services. This includes products and services sourced in Australia or overseas and extends beyond direct Suppliers.

 

3. Scope of this Policy

This policy applies to all persons working for or on behalf of, or providing services to, the Company in any capacity, including all Suppliers, employees, directors, officers, agency workers, contractors, consultants and any other third-party representatives (‘Parties’).

This policy outlines the Company’s approach to reducing the risk of modern slavery within our business and all supply chains.

 

4. The Company’s Operations

The Company is a privately-owned, Brisbane headquartered, medical device manufacturer and channel management entity founded by Dr Neville Henry AM and Associate Professor Michael Sinnott. The Company has been successfully trading for more than 19 years. The company works with contract manufacturers and suppliers to produce a range of multi-award-winning safety medical devices. The Company has a long established and growing distribution channel servicing over 10 different healthcare market segments.

 

5. The Company’s Response to Modern Slavery

As a company dedicated to improving safety in workplaces, committed to eliminating Modern Slavery in all forms by eliminating Modern Slavery from its business and supply chains.

The Company complies with all Australian Workplace Relations Legislation (including but not limited to the Fair Work Act 2009 (Cth)) and provides all employees with at least the minimum guaranteed entitlements of an employee in Australia. Each employee is given access to the Company’s HR Policy, which is set up to follow the guidelines stipulated by the Fair Work Act 2009, the Queensland Anti- Discrimination Act 1991, and the Australian National Employment Standards (NES).

The Company has also established processes to ensure that our employees enjoy a safe workplace. As part of these efforts, we will continue to invest in training programs that promote both physical and psychological safety and wellbeing of our team members.

The Company has a zero-tolerance policy in relation to Modern Slavery in its Supply Chains. We regularly review our procurement policy and procedures to ensure that suppliers adhere to the Company’s Modern Slavery Policy. The existing supplier selection process includes an assessment of ethical trading practices around employment including requirements around:

• • Compliance with the applicable national laws related to employee management
  • Employees working of their own free accord
  • Meeting national minimum age requirements
  • Meeting national and industry related minimal wage requirements
  • Practices compliant with workplace safety policies
  • Acknowledgment of the Company’s Modern Slavery Policy.

 

Suppliers are requested to fill the Ethical Trading Questionnaire as part of our ISO 13485:2016- certified Supplier Evaluation procedures.

The Company has undertaken to train all relevant employees on modern slavery and human trafficking. The Company has also undertaken to ensure that all employees have access to any additional information and support they may require with regard to human trafficking, forced labour, child labour, servitude and slavery.

All employees and suppliers will be expected to comply with this policy and the standards provided therein and will be provided a copy of this policy as soon as reasonably practicable upon engagement with the Company.

This policy will be used to underpin and inform any statement on Modern Slavery that the Company is required to produce in its compliance with Modern Slavery Legislation, as required from time to time

 

6. Breaches of this Policy

Employees are required to advise the Company’s management of any instances or suspected instances of Modern Slavery in the Company and the Company’s supply chain.

Any supplier who the Company is made aware of that is not complying with the Company’s approach to Modern Slavery will be provided a reasonable opportunity to respond to any allegations, failing which the Company will cease involvement with that entity or individual.

 

7. Responsibility

The Company’s Top Management, as defined by the Company’s Quality Manual Section 05 Management Responsibility, is responsible for identifying and overseeing modern slavery risks that arises in relation to the goods and services that the Company provides. It is also the responsibility of the Top Management to provide necessary resources and support to all employees to achieve Company’s zero tolerance approach to Modern Slavery.

 

8. Reporting Concerns of Modern Slavery

A key part of Company’s zero tolerance approach to Modern Slavery is enabling all employees/officers/directors, suppliers or any third party (including the public) to speak up when there are reasonable grounds to suspect that the Company, its employees/officers/directors, or suppliers are not acting in accordance with Modern Slavery Legislation or this policy.

Reports of instances or suspected instances of Modern Slavery can be made as follows:

1. 1. Calling the Company on 07 3844 1182;
   2. Emailing the Company at hello@qlicksmart.com or enquiries@smartstream.com.au ; or
   3. Speaking directly to your manager or direct contact at the Company

Alternatively, in Australia, the Australian Federal Police, who are responsible for investigating suspected cases of Modern Slavery, can be contacted on 131 237 or 02 5126 0000. Contact can be made anonymously.

 

For more details about the Company’s whistleblower policy employees can refer to the HR Policy.