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Modern Slavery Policy
Effective Date: [01/JUL/2024]

 

1. Policy Statement

GXN Group Pty Ltd is committed to maintaining the highest ethical standards in all its operations and interactions. We unequivocally oppose modern slavery in any form, including human trafficking, forced labour, child labour, and all forms of exploitation. This policy outlines our commitment to preventing, detecting, and addressing any occurrence of modern slavery within our business and supply chain, in accordance with the Modern Slavery Act 2018 (Cth), Australian legislation, and international standards.

We recognize that modern slavery is a complex and pervasive issue, and we are committed to taking all necessary steps to mitigate any risk of modern slavery practices within our operations and supply chain.

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2. Scope

This policy applies to:

  • All employees of GXN Group Pty Ltd across all operations, including full-time, part-time, temporary, and contracted staff.

  • Our suppliers, subcontractors, and business partners globally, especially those involved in manufacturing, distribution, and provision of medical consumables and related products.

  • Any third parties engaged in activities that may impact the company, including service providers and consultants.

 

3. Definitions

  • Modern Slavery refers to situations where coercion, threats, or deception are used to exploit individuals and deprive them of their freedom. It includes, but is not limited to:

    • Human trafficking

    • Forced labour

    • Child labour

    • Debt bondage

    • Slavery-like practices

  • Supply Chain refers to the entire network of entities, both direct and indirect, that provide products or services that are used in the company’s business operations.

 

4. Commitment to Ethical Business Practices

We are dedicated to ensuring that:

  • No employee or worker within our company or supply chain is subjected to any form of slavery or exploitation.

  • Our suppliers and contractors adhere to fair labour practices and comply with all applicable labour laws and human rights standards.

  • Due diligence procedures are implemented to assess and mitigate risks of modern slavery across our supply chain, including thorough checks of potential suppliers and contractors.

  • Education and training are provided to our employees and suppliers on identifying and addressing modern slavery issues.

 

5. Due Diligence Process

Our company takes the following steps to prevent and address modern slavery risks:

  • Supplier Code of Conduct: We will ensure that all suppliers, contractors, and business partners are aware of and adhere to our Supplier Code of Conduct, which explicitly prohibits modern slavery and exploitation in any form. This Code will be integrated into contracts and agreements with suppliers.

  • Risk Assessment: A regular and ongoing risk assessment will be conducted to identify and assess potential modern slavery risks within our operations and supply chain. The assessment will include an analysis of geographical regions, sectors, and suppliers where the risk of modern slavery is high.

  • Supplier Audits: We will conduct periodic audits of our suppliers, both on-site and through third-party assessments, to ensure compliance with modern slavery standards. Where appropriate, we may request documentary evidence of compliance with labour standards.

  • Contractual Clauses: All contracts with suppliers will include specific clauses related to modern slavery and require immediate reporting of any suspected or known incidents of slavery or exploitation.

 

6. Employee Training

GXN Group Pty Ltd will provide regular training for employees at all levels on:

  • The risks and indicators of modern slavery.

  • Our company’s zero-tolerance approach to modern slavery.

  • How employees can report concerns regarding modern slavery within our operations or supply chain.

  • How to engage responsibly with suppliers and stakeholders on modern slavery issues.

Training will be mandatory for staff in procurement, human resources, and any other department directly involved with suppliers and partners.

 

7. Reporting and Whistleblowing

We encourage all employees, suppliers, contractors, and other stakeholders to report any concerns or suspicions of modern slavery in our operations or supply chain. Reports can be made confidentially and without fear of retaliation, through the following channels:

  • Whistleblower Hotline: 1800 954 116

  • Email: info@gxngroup.com

  • Management: Employees may report directly to their manager or the designated compliance officer.

All reports will be investigated promptly, and appropriate corrective actions will be taken where necessary.

 

8. Corrective Actions and Remediation

If modern slavery is identified, GXN Group Pty Ltd will take immediate and appropriate action to address the situation. This may include:

  • Working with the affected supplier or business partner to rectify the issue, including providing support to victims of modern slavery.

  • Terminating contracts or relationships with any suppliers or contractors found to be involved in modern slavery practices.

  • Cooperating with law enforcement and relevant authorities to ensure legal remedies are pursued.

We are committed to supporting affected individuals in their recovery and providing them with access to appropriate support services, including legal, psychological, and social assistance.

 

9. Monitoring and Review

This policy will be reviewed annually to assess its effectiveness in preventing modern slavery and to ensure that it is aligned with current best practices and legal requirements. We will evaluate:

  • The effectiveness of our due diligence processes.

  • The actions taken in response to any modern slavery incidents or risks.

  • The feedback from stakeholders and employees regarding the policy.

 

10. Accountability

The implementation and oversight of this policy are the responsibility of the GXN Group Pty Ltd senior leadership team. The Director, along with senior management, will ensure that this policy is followed and that the necessary resources are allocated to combat modern slavery. The company’s compliance officer will report to the board on the effectiveness of our efforts to prevent modern slavery.

 

11. Policy Compliance

Failure to comply with this policy, or engaging in modern slavery practices, will result in disciplinary action, up to and including termination of employment or contractual agreements.

 

This policy reflects GXN Group Pty Ltd ongoing commitment to ethical practices and the protection of human rights. By taking a proactive stance against modern slavery, we aim to contribute to a fairer and more just world while upholding the highest standards of integrity.

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