MODERN SLAVERY POLICY

1.    PURPOSE

1.1.  Modern slavery is a severe violation of fundamental human rights that occurs when a person is coerced into work and exploited for personal or commercial gain.

1.2.  While the Company is not subject to the reporting requirement set out in the Modern Slavery Act 2018 (the Act), it is committed to limiting the risk of modern slavery occurring within its own business, within its supply chains or through any other business relationship.

2.    DEFINITIONS

2.1.  “Associated Entities” has the meaning given to that term by section 50AAA of the Corporations Act.

2.2.  “The Company” means XENON Systems Pty Ltd ACN 073 339 316 and/or any of its Associated Entities.

3.    POLICY APPLICATION

3.1.  This policy applies to all persons working for the Company or on its behalf in any capacity, including employees at all levels, directors, officers, agents, secondees, volunteers, interns, contractors, external consultants, third-party representatives and business partners (referred to inclusively as “personnel” below).

3.2.  This policy does not form part of any employee’s contract of employment and the Company may amend it at any time.

4.    THE COMPANY’S RESPONSE TO MODERN SLAVERY

4.1.  All employment with the Company is voluntary.

4.2.  The Company does not use or condone child or forced labour in any of its operations or premises and works to ensure that these practices are not present in its workforce or supply chain.

4.3.  The Company does not tolerate any form of unacceptable treatment of workers, including but not limited to the exploitation of children, physical punishment or abuse, or involuntary servitude.

4.4.  The Company abides by all laws and regulations regarding pay practices and the classification of employment according to job level and status.

4.5.  Where the Company is made aware of modern slavery practices in its own business or within its supply chain, the Company will investigate all claims and if valid, resolve the issue in line with the values expressed in this policy.

4.6.  The Company provides training with the aim of educating all Employees and Contractors on signs that could indicate modern slavery, due diligence practices for engaging suppliers, auditing existing suppliers and what action an employee or contractor can take if they have a concern in relation to modern slavery.

4.7.  The Company conducts risk assessments to determine which parts of the business and supply chains are most at risk from modern slavery to ensure focus on those areas.

5.    THE COMPANY’S SUPPLY CHAIN

5.1.  The Company expects its suppliers to have similar values to the Company in relation to modern slavery.

5.2.  The Company is committed to introducing anti-slavery obligations in all supplier contracts. As part of their contractual obligations, the Company seeks undertakings that suppliers comply with all laws and regulations in force which relate to modern slavery.

6.    TRAINING

6.1 The Company will provide training which covers:

  • Various forms of modern slavery in which people can be held and exploited,
  • The Modern Slavery Act 2018,
  • How to identify and report modern slavery in and around the workplace.

6.2 Personnel agree to participate in such training provided by the Company from time to time.

7.    COMPLIANCE WITH THIS POLICY AND REPORTING

7.1.  Personnel must ensure that they read, understand and comply with this policy.

7.2.  Personnel must notify their manager as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future.

7.3.  Personnel are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

7.4.  If personnel believe or suspect a breach of this policy has occurred or that it may occur they must notify their manager as soon as possible.

7.5.  If personnel are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager.

7.6.  We aim 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. The Company is committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.

8.    BREACHES OF THIS POLICY

8.1.  Any breach of this policy will be taken seriously and dealt with on a case-by-case basis.

8.2.  Any employee who breaches this policy may face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

8.3.  The Company may terminate its relationship with other individuals and organisations working on its behalf if they breach this policy.

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Version: 24-May-2021.