LEGAL
Visionet Global Modern Slavery Policy & Procedure
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About this Policy
Visionet Systems and its group of companies (“Visionet”) is an Equal Employment Opportunity (EEO) provider who strictly prohibits the use of modern slavery, human trafficking and child labour in its operations, We have a zero tolerance approach to modern slavery and are committed to act ethically and with integrity in all our business dealings and relationships and to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
Visionet is committed to ensure transparency in its own business and in its approach to tackling modern slavery throughout its supply chains, consistent with its disclosure obligations under the Modern Slavery Act 2015. Visionet expects the same high standards from all of its contractors, suppliers and other business partners and, as part of its contracting processes, includes specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and expect that its suppliers will hold their own suppliers to the same high standards. -
Purpose and Scope
The purpose of this policy is for Visionet to:
a)Set out its responsibilities, and of those working for and on its behalf, in observing and upholding its position on modern slavery and human trafficking; and
b)Provide information to those working for and on its behalf on how to identify and report concerns regarding modern slavery and human trafficking.
i: Who does this Policy apply to?
This policy extends to all persons working for us or on our behalf in any capacity, including employees at all levels, officers, consultants, contractors, interns, probationer, trainee, apprentice, casual workers, volunteers, third-party representatives, business partners and agency works of Visionet. This policy does not form part of any employee's contract of employment and we may amend it at any time.
For the purpose of this policy, the terms Complainant means any person who has lodged complaint for breach of this policy against Respondent and Respondent means any person against whom a complaint of being involved in any activities leading to modern slavery has been lodged. -
What is Modern Slavery?
Modern Slavery is a crime and a violation of fundamental human rights. It is a term used to encompass slavery, servitude, forced compulsory labour, bonded and child labour and human trafficking, all of which include the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.
The latest International Labour Organisation estimates show there are 152 million children in child labour and 25 million children and adults in forced labour globally. As product manufacturing and distribution supply chains are often complex, we must ensure we address the eradication of Modern Slavery throughout our entire supply chain and not just focus on the end product. We must also consider our third-party and service providers employed to support both the product and service offer we give to our customers and stakeholders.
There is no typical victim of Modern Slavery, and some victims do not understand that they have been exploited and are entitled to help and support. However, the following key signs could indicate that someone may be a victim of Modern Slavery or human trafficking:
i: The person is not in possession of their own passport, identification, or travel documents.
ii: The person is acting as though they are being instructed or coached by someone else.
iii: The person allows others to speak for them when spoken to directly.
iv: The person is dropped off and collected from work.
v: The person avoids eye contact, is withdrawn or appears frightened.
vi: The person does not seem to be able to contact friends or family freely.
vii: The person has limited social interaction or contact with people outside of their immediate environment.
The above list is not exhaustive or holistic. A person may display several the indicators set out above, but they may not necessarily be a victim of slavery or trafficking. -
Responsibility for the Policy
4.1 Visionet’s Board of Directors are responsible for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
4.2 The Global HR Head as primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
4.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
4.4 You are 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 hr@visionet.com.
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Your Responsibilities and How to Raise a Concern
5.1 You must ensure that you read, understand and comply with this policy.
5.2 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.
5.3 You must notify hr@visionet.com as soon as possible if you believe or suspect that a breach of this policy has occurred, or may occur in the future.
5.4 You 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.
5.5 If you believe or suspect that a breach of this policy has occurred or that it may occur you must notify hr@visionet.com as soon as possible. You should note that where appropriate, and with the welfare and safety of local workers as a priority, we may give support and guidance to our suppliers to help them address coercive or exploitative work practices in their own business and supply chains.
5.6 If you 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 hr@visionet.com.
5.7 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. We are 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. 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 HR SPOC immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Visionet’s Global Workplace Conduct Investigation Policy.
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Training and Communication
6.1 Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
6.2 Our commitment to addressing the issue of modern slavery in our business and supply chains must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate on an ongoing basis.