Type: Policy
Classification: Strategic
Policy Number: SCS2021004
Version: 1.2
Updated: August 2021
The term modern slavery describes situations where coercion, threats or deception are used to exploit people, and undermine their dignity and freedom. Modern slavery practices violate universally recognised human rights, are crimes and pose a serious business risk to Sydney Catholic Schools’ (SCS) operations and reputation.
Heeding Pope Francis’ call to end modern slavery, Archbishop Anthony Fisher OP committed the Archdiocese of Sydney, including SCS, to a program directed towards the eradication of modern slavery and human trafficking in the Archdiocese through practical measures such as anti-slavery supply chain strategies, anti-slavery education and engagement initiatives and anti-slavery welfare servicesThe purpose of this policy is to give effect to that commitment. SCS seeks to prevent, and ultimately to help to eradicate by 2030, modern slavery by managing and mitigating modern slavery risk within our business operations and supply chains.
Through this policy, SCS will work to ensure that modern slavery does not flourish within our operations, business relationships and extended supply chains. This policy also provides a robust framework to ensure compliance with the reporting requirements of the Commonwealth Modern Slavery Act 2018 (the Act).
- This policy applies to all SCS staff. In this policy SCS staff means employees, volunteers, interns, consultants, members of religious orders engaged in schools, trainees, labour hire employees, and committee members.
- This policy also applies to suppliers where specified. A supplier is any party and their workers, including their employees, agents, volunteers, contractors, sub-contractors, consultants and business partners, that supplies goods or services to SCS in accordance with a written agreement.
Failure to comply will lead to disciplinary action which may include termination of employment. SCS will alert authorities should modern slavery be found in a supplier’s business model. - While SCS is committed to working with its suppliers to rectify any identified instances of modern slavery, SCS retains the right to terminate our relationship with individuals, suppliers and organisations working on our behalf or engaged by SCS if they breach this policy.
Catholic social teaching calls for the dignity of work, the rights of workers and advancing the common good. These are the principles that guide this policy.
The following principles inform the implementation of this policy within SCS;
3.1 SCS has zero tolerance for modern slavery, and SCS will not knowingly use or contribute to modern slavery practices in any form.
3.2 SCS will actively work to identify and eliminate modern slavery practices from our operations, business partnerships and supply chain.
3.3 Any form of exploitative treatment, punishment, abuse of labour rights, coercive control (physical, mental, psychological or financial) of SCS staff or workers in SCS’ supply chain is unacceptable.
3.4 SCS shall at all times work to comply with all relevant laws and regulations regarding recruitment, remuneration, working conditions and freedom of association.
3.5 SCS’ final purchasing decisions shall not be based on price alone. Ethical business processes are an essential part of our value for money and ‘fit for purpose’ considerations. This includes consideration of living wage mechanisms and responsible recruitment of workers in SCS’ supply chain.
3.6 SCS will continue to support our staff and suppliers to assess and address modern slavery risks and take action to improve transparency, traceability and accountability for modern slavery practices and impacts in our collective supply chains.
Modern slavery is a term used to describe serious exploitation of people.
According to the Australian Government, practices that constitute modern slavery can include:
- human trafficking;
- slavery;
- servitude;
- forced labour;
- debt bondage;
- forced marriage; and
- the worst forms of child labour.
To implement this policy in practice the following actions are required of SCS staff and suppliers.
5.1 SCS leadership
5.1.1 To further the Archbishop’s commitment for the Archdiocese, including SCS, to work to eradicate modern slavery, the SCS Board has overall responsibility for ensuring this policy and its implementation complies with relevant Catholic social teachings, legal and ethical obligations and relevant policies of the Archdiocese including the Catholic Archdiocese of Sydney’s Guide to Business Practice.
5.1.2 The Executive team has ultimate responsibility for managing modern slavery risk within SCS.
5.1.3 All levels of management are responsible for ensuring SCS staff are aware of this policy, are provided with regular training in its application and have sufficient resources for its implementation.
5.2 SCS staff and suppliers
5.2.1 SCS staff, and suppliers are expected to implement the following measures:
- ensure that the identification, prevention, management and mitigation of modern slavery risk is a core responsibility of all SCS staff and workers in SCS’ supply chain;
- ensure that business operations or relationships that knowingly support, facilitate or encourage worker exploitation or modern slavery practices are strictly forbidden; and
- report any actual or suspected activity that could breach this policy immediately.
5.2.2 SCS staff will use pro forma SCS contracts with suppliers wherever this is possible. The pro forma contracts include anti-slavery clauses. Anti-slavery clauses shall be incorporated into procurement tenders and into contracts with provisions relating to the right to audit, review documentation and interview workers included in contracts with high risk suppliers.
5.2.3 SCS will actively engage with suppliers to promote this policy and assist to develop their capabilities to identify and manage modern slavery risks.
5.2.4 SCS expects suppliers to share our goals and values in relation to ending modern slavery.
5.2.5 Suppliers are expected to support SCS efforts to assess the levels of risk within their operations and supply chain, and to gauge their commitment and capability to manage modern slavery risks.
5.2.6 Suppliers will demonstrate to SCS how they identify, prevent, manage and mitigate modern slavery risk in their operations and supply chains.
5.2.7 SCS will undertake supplier reviews (including self-assessment questionnaires) to assess levels of modern slavery risk, commitment and capacity to manage identified risks. This includes any new supplier that wants to do business with SCS.
5.2.8 SCS will undertake to work with suppliers, where it is identified that they may be non compliant with the Modern Slavery Act 2018 (Cth), and where SCS determines that there is both a willingness and evidence that the supplier is working to eliminate modern slavery from its supply chain.
5.3 What to do if slavery is suspected or discovered – reporting
5.3.1 SCS staff shall immediately report any suspected violations of this policy or other illegal or unethical conduct related to modern slavery to their line manager for escalation to the Finance and Property Directorate.
5.3.2 Information is confidential and there will be no retribution or retaliation for reports made in good faith.
5.3.3 Suppliers are also required to report to SCS suspected or actual modern slavery practices, indicators or red flags immediately without fear of retribution, retaliation or loss of business with SCS. This applies where suppliers have not knowingly engaged in modern slavery practices. SCS commits to working with our suppliers to address issues, ensure effective remedy and implement prevention measures.
5.3.4 If a supplier or any other person outside SCS provides information to an SCS staff member about suspected or actual modern slavery practices, indicators or red flags within SCS or their supply chain, the SCS staff member must immediately pass on the information to their line manager for escalation to the Finance and Property Directorate.
5.3.5 If a supplier has been shown to be, or there is reasonable cause to believe the supplier is, engaging in modern slavery practices, the incidence should be reported to the Board, with recommendations as to whether SCS continues its commercial relationship with that supplier.
If you have any questions about this Policy or would like further information, please contact the Finance and Property Directorate on procurement.scs@syd.catholic.edu.au or Phone (02) 9569 6111.
- Policy Number: SCS2021004
- Document Rescinds / Replaces: FAS201802-1.1
- Policy released: 9 August 2021
- Review by: 9 August 2023
- Approved by: SCS Board
- Document Owner: Director, Finance and Property