Modern Slavery & Responsible Sourcing Policy
Our commitment to acting ethically and tackling modern slavery across the ATI Group and our supply chain.
1. Introduction
1.1 Purpose
ATI Global Limited ACN 634 158 204 (ATI) together with its subsidiaries (collectively referred to in this Policy as the ATI Group, we or our) has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings and relationships. The ATI Group is also committed to ensuring there is transparency in its approach to tackling modern slavery, consistent with its disclosure obligations under the Modern Slavery Act 2018 (Cth) and any other similar laws in jurisdictions where we operate.
This Policy forms part of our overall risk management framework.
2. Application of this Policy
2.1 ATI Group
This Policy applies to any person working for or on behalf the ATI Group in any capacity.
2.2 Non-Compliance
Intentional or repeated non-compliance with this Policy is considered especially serious and may result in disciplinary action, up to and including termination of your employment or engagement with the ATI Group.
You may terminate existing relationships with a Supplier whose operations do not align with these standards. You should liaise with the Legal Department to ensure appropriate language is included in contracts so that responsible sourcing requirements are contractually binding.
3. Core Principles
We must a) seek to limit unethical and illegal business practices with respect to modern slavery; b) report any actual or suspected instances of modern slavery in any part of ATI Global or its supply chain; and c) abide by all applicable laws, rules and regulations.
4. Modern Slavery
4.1 What is Modern Slavery?
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, forced marriage, debt bondage and human trafficking, whether of adults or children, all of which deprive individuals of liberty and exploit them for personal or commercial gain.
4.2 Examples of Modern Slavery
Some examples of Modern Slavery include: a) Slavery: Where a person is forcibly detained by a people smuggler and then sold to another person or company and forced to work with little or no remuneration or food. b) Forced Labour: A group of people are employed to work in a factory. Their wage is later reduced to below minimum wage. When they complain or threaten to leave the employer threatens the lives of the workers families. c) Debt Bondage: A person accepts a job as a skilled worker overseas. Their employer advises them they will be required to pay a recruitment fee and repay their
flight costs. These costs are greatly exaggerated. On arrival the persons passport is confiscated until such time as they can repay the debt. d) Child Labour: Where a child is forced to work for little or no remuneration to build computer products. Those computer products are then purchased for use in business activities.
5. Procurement
You must review this Policy and the Procurement Policy when identifying and partnering with Suppliers to determine the appropriateness of any purchase. It is particularly important for you to understand the ‘Procurement Principles’ in the Procurement Policy, in addition to any responsible sourcing commitments in this policy.
6. Communication with Suppliers
You must address the issue of modern slavery with all Suppliers at the outset of any new relationship and reinforce it, as appropriate. All Suppliers must be provided with, and must complete (to the extent possible and practicable in the circumstances), the Supplier Questionnaire (Modern Slavery) and attest to the Supplier Code of Conduct before we purchase anything from them. In some circumstances it may not be possible or practicable to have a Supplier complete the above. For example, large suppliers like Amazon Web Services and Microsoft are unlikely to engage on ATI Group documents. In these situations, you should ask Suppliers, or check a Supplier’s website, for materials that detail how they mitigate or minimise modern slavery. You should carefully consider whether such policies and practices are aligned with the ATI Group’s standards. You should discuss with the Legal Department where you are unsure about a Supplier’s alignment with the ATI Group’s position on modern slavery.
7. Reporting Instances of Modern Slavery
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of everyone at the ATI Group and everyone we hire or contract. You are required to avoid any activity that might lead to, or suggest, a breach of this Policy. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business or supply chain at the earliest possible stage. If you believe or suspect a breach of this Policy has occurred or may occur or are unsure of anything as it relates to this Policy, you should notify the Legal Department.
We recognise that there may be times where you believe it is inappropriate or difficult to discuss these matters. In those cases, you may make reports via the whistleblowing reporting channels. Whistleblowing reports may be made in a way that either identifies a person, or anonymously. Please refer to the Whistleblowing Policy for further information about making such reports.
You will not suffer any adverse employment or contract decision as a result of bringing to the attention of the Legal Department or any director or supervising person, in good faith, any known or suspected breach of this Policy.
8. Responsibility for this Policy
Group Legal has 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. 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.
9. Risk Awareness & Training
We will provide regular training to Team Members who procure goods and/or services in
relation to this Policy. This will include training on the business and its supply chains and how to identify modern slavery practices. This training will also form part of the induction process for all new Team Members.
Our commitment to addressing the issue of modern slavery in our business and supply chains must be communicated to all Suppliers at the outset of our business relationship with them and reinforced, as appropriate, on an ongoing basis.
10. Board Endorsement
The ATI board has overall responsibility for ensuring this policy complies with both legal and ethical obligations and for approving the annual modern slavery statement. No changes may be made to this Policy without board approval.
11. Interpretation
11.1 Definitions
ATI Group means ATI Global Limited ACN 634 158 204 and any of its successors together with any of its Related Bodies Corporate. Corporations Act means the Corporations Act 2001 (Cth). Legal Department means internal legal counsel for the ATI Group. Related Bodies Corporate has the meaning given to it in the Corporations Act. Supplier means a supplier of goods or services to an ATI Group business, including any agent, contractor, external consultant or business partner. Supplier Code of Conduct means the ATI Global Supplier Code of Conduct as included as Schedule 1 to this Policy. Supplier Questionnaire (Modern Slavery) means the Supplier Questionnaire (Modern Slavery) as included in Schedule 2 to this Policy. Team Member means an employee, contractor, agent or director of the ATI Group.
11.2 References
This Policy should be read in conjunction with the following governing documents:
- Procurement Policy;
- Anti-Bribery & Corruption Policy;
- Risk Management Policy; and
- Whistleblowing Policy.
12. Updates, Review & Ownership
This Policy may be updated from time to time. The Policy will be maintained at all times on Bamboo HR. If you have any questions about this Policy please contact the Compliance Officer or a member of the Global Legal Team.