ANTI – MODERN SLAVERY
Anti – Modern Slavery Policy
ANTI – MODERN SLAVERY POLICY
The purpose of this policy is to ensure LMI Group’s commitment to utilising ethical suppliers and ensuring that any modern slavery risks in LMI Group’s supply chain are identified and that steps are taken to address these risks.
2.1. This policy applies to any person who is employed by, acts for, or represents LMI Group, including directors, officers, employees (whether permanent, fixed-term or temporary), contractors, consultants and secondees wherever located (collectively referred to as Employees in this policy). 3.1. LMI Group has a zero tolerance approach to all forms of modern slavery and human trafficking within its business and within its supply chain and is committed to acting ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking is not taking place in its own business or in any of its supply chains.
2.2. All Employees are required to familiarise themselves and comply with this policy, including any future updates that may be issued from time to time by LMI Group.
3. Policy Statement
3.1. LMI Group has a zero tolerance approach to all forms of modern slavery and human trafficking within its business and within its supply chain and is committed to acting ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking is not taking place in its own business or in any of its supply chains.
4. Policy Compliance
4.1. The LMI Group is committed to stamping out all forms of slavery and human trafficking.
4.2. In performing your role all staff shall:
4.2.1. comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes from time to time in force including but not limited to the Modern Slavery Act 2015 (UK), Criminal Code Act 1995 (Aust), Crimes Legislation Amendment (Slavery, Slavery-like Conditions and People Trafficking) Act 2013 (Aust) and its equivalent in the jurisdiction(s) in which you perform your role. And;
4.2.2. not engage in any activity, practice or conduct that would constitute an offence under Sections 1, 2 or 4, of the Modern Slavery Act 2015 (UK) and Section 268.15 of the Criminal Code Act 1995 (Aust)
4.3. Compliance Measurement Title: Anti – Modern Slavery Policy Version: 1.0-20191104 Document Owner: Human Resources Date: 04/11/2019 Page 2 of 3
4.3.1. The Human Resources and Finance Departments will verify compliance to this policy through various methods, including but not limited to, internal and external audits, and feedback.
4.4.1. Any breach of these provision will be considered extremely serious and will lead to disciplinary action to the full extent of the law and reporting to the appropriate law enforcement agency.
4.5.1. There are no exceptions to this policy.
5. Roles and Responsibilities
5.1. To underpin our policy commitments, LMI Group shall endeavour to;
5.1.1. Conduct risk assessments to determine which parts of our own business and which of our supply chains are most at risk from modern slavery so we can focus our efforts on those areas most ‘at risk’
5.1.2. Where appropriate, as informed by our risk assessment, engage directly with new suppliers in respect of our anti-slavery policy to gain a proper understanding of the measures they have in place to ensure that modern slavery is not occurring within their own businesses.
5.1.3. Our contractual documentation will incorporate specific prohibition against slavery or servitude, the use of forced, compulsory or trafficked labour, and the use of child labour in line with this policy.
5.1.4. We also make provision for our contracted suppliers to hold their own suppliers to the same standards. Policy Compliance
5.2. You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of slavery and other forms of servitude are the responsibility of all those working for us or under our control. All Employees are required to avoid any activity that might lead to, or suggest a breach of this policy.
5.3. You must notify your manager as soon as possible if you believe or suspect that a conflict with, or breach of, this policy has occurred, or may occur in the future. Any Employee who breaches this policy will face disciplinary action, which could result in termination of employment.
6. How to raise a concern
6.1. All Employees have a responsibility to help detect, prevent and report instances not only of slavery or servitude, but also of any other suspicious activity or wrong doing in connection with LMI Group’s business. Group is committed to ensuring that all Employees have a safe, reliable and confidential way of reporting any suspicious activity. You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage with your manager. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries or concerns, these should be raised with your manager.
6.2. If you are not comfortable, for any reason, with speaking directly to your manager, Group has a Whistleblower Policy which affords certain protections against reprisal, harassment or demotion for making the report. Title: Anti – Modern Slavery Policy Version: 1.0-20191104 Document Owner: Human Resources Date: 04/11/2019 Page 3 of 3
7.1. Australia 7.1.1. Modern Slavery Act 2018 (Cth) 184.108.40.206. https://www.legislation.gov.au/Details/C2018A00153
7.1.2. Criminal Code Act 1995 (Cth) 220.127.116.11. https://www.legislation.gov.au/Details/C2020C00245
7.1.3. Crimes Legislation Amendment (Slavery, Slavery-Like Conditions and People Trafficking) Act 2013 (Cth) 18.104.22.168. https://www.legislation.gov.au/Details/C2013A00006
7.2. New Zealand 7.2.1. New Zealand Bill of Rights Act 1990 22.214.171.124. http://www.legislation.govt.nz/act/public/1990/0109/latest/DLM224792.html
7.2.2. Crimes Act 1961 126.96.36.199. http://www.legislation.govt.nz/act/public/1961/0043/latest/whole.html
7.2.3. United Kingdom 188.8.131.52. Modern Slavery Act 2015 184.108.40.206.1. http://www.legislation.gov.uk/ukpga/2015/30/contents/enacted
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