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Modern Anti-Slavery Policy

Introduction

Purpose

Charterhouse Recruitment Pty Ltd is resolved to operating all of its business activities to the highest standards of business ethics and integrity. We are committed to providing a respectful environment for all our employees, free from discrimination, abuse and exploitation.

There is no globally agreed definition of modern slavery rather the term is used to cover a range of exploitative practices including human trafficking, slavery, forced labour, child labour and debt bondage. We are committed to ensuring there are no modern slavery concerns in our business or supply chain.

Charterhouse Recruitment is one of Australia's leading recruitment agencies. We specialise in Permanent Recruitment, Contract Recruitment & Executive Search and have a proven track record in identifying and placing superior candidates across our chosen disciplines.

Accordingly, we commit to assessing and monitoring the risks of modern slavery in our business through our own supply chain and taking action to eliminate such practices.

Charterhouse Recruitment’s approach to monitoring modern slavery is as follows:

  • Recognise the leverage we have to influence change within our community and consider how our actions and business practices could influence and contribute where supplier pricing is inappropriately low.
  • Build meaningful relationships with external stakeholders by:
    – Providing awareness of modern slavery through training
    – Raising awareness of our expectations via client agreements
    – Identifying and responding to inappropriate practices
  • Adopt a risk management approach with both internal and external stakeholders to identify areas where modern slavery may be present and monitor the risks where required.

Our company’s policy on business conduct and ethics includes elements that address several areas that are central to how we promote ethical and responsible behaviour through our values:

  • High ethical standards and leadership by example
  • The safety of all employees and visitors to our sites
  • Encouraging our people to reach their potential
  • Workplace relations that value communication, consultation, co-operation
  • Respecting our customers and delivering our promises


Our Commitment

Charterhouse Recruitment is committed to upholding human rights, fair working conditions and environmental protection.

In accordance with the expectations of our customers, the community, and the requirements of the Law, we endeavour to always operate responsibly within the community and we expect the same from our suppliers.

Maintaining a reputation for the highest legal, moral and ethical standards in our dealings with our customers and other key stakeholders is critical for our ongoing success. This policy statement has been developed to complement our core values of integrity, trust and acting responsibly.

We are committed to working with our suppliers to help improve their labour and environmental practices. Policy Statement 001 Rev 1.0 Page 2 20 May 2021


Our Principles:

Expectations

We expect our suppliers to support the ethical standards set out in this policy statement with regard to workplace safety, environment, and fair pay and employment conditions.

These documents set out the standards that we expect all of our suppliers to comply with when producing and supplying products for Charterhouse Recruitment, no matter where they operate in the world. We recognise that full compliance with these criteria may take time for some suppliers, and we are committed to working with our suppliers to implement improvement plans and help them achieve compliance.

Bribery and Corruption

  • We shall not engage in acts of bribery and corruption and shall not falsify documents and records

Labour Rights

  • Employment is freely chosen
  • There is no forced, bonded or involuntary prison labour
  • Workers are not required to lodge deposits or their identity papers with their employer and are free to leave their employer after reasonable notice

Freedom of association and the right to collective bargaining are respected

  • The employer adopts an open attitude towards the activities of trade unions and their organisational activities
  • Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively
  • Worker’s representatives are not discriminated against and have access to carry out their representative functions in the workplace
  • Where the right to freedom of association and collective bargaining is restricted under Law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining

Working Conditions

  • Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers
  • A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health in the working environment
  • Access to clean toilet facilities and to clean and drinkable water and, if appropriate, sanitary facilities for food storage shall be provided
  • We will ensure that personal protective equipment is available and workers are trained in its use. Safeguards on machinery will meet or exceed local laws

Child Labour

Charterhouse Recruitment supports ILO Convention 138 with regard to the appropriate age of workers and will not work with suppliers who use child labour.

Child labour refers to work that:

  • Is mentally, physically, or morally harmful to children;
  • Can negatively affect their mental, physical, or social development, and
  • Interferes with their schooling:
    – by depriving them of the opportunity to attend school;
    – by obliging them to leave school prematurely; or
    – by requiring them to attempt to combine school attendance with excessively long and heavy work.

In short: child labour is work that deprives children of their childhood, their potential and their dignity, and is harmful to their physical and mental development. Policy Statement 001 Rev 1.0 Page 3 20 May 2021

Living Wages

  • Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs and to provide some discretionary income
  • All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid
  • Deductions from wages as a disciplinary measure or any deductions from wages not provided for by Law shall not occur without the expressed permission of the worker concerned. All disciplinary measures should be recorded

Working Hours

  • Working hours comply with any Law and benchmark industry standards, whichever affords greater protection

Discrimination

  • There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation

Harsh or Inhumane Treatment

  • Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited

Entitlement to Work and Immigration

  • Only workers with a legal right to work shall be employed or used by Charterhouse Recruitment
  • All workers, including employment agency staff will be validated by Charterhouse Recruitment for their legal right to work by reviewing original documentation
  • Charterhouse Recruitment have processes to enable adequate control over agencies with regards to the above points and related legislation

Compliance with the Policy

Charterhouse Recruitment expects all its suppliers to comply with all aspects of this policy statement and will be extending its coverage of audited facilities and compliance monitoring processes to include these standards.

Charterhouse Recruitment is committed to working in partnership with its suppliers to help achieve compliance with this policy statement. In the event where any supplier is unwilling or unable to demonstrate continuous improvement towards full compliance with our standards, the trading agreement between Charterhouse Recruitment and the supplier will be terminated.