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Anti-Slavery
Policy

Atturra Limited ACN 654 662 638 and its subsidiaries (collectively referred to as Atturra)recognise that modern slavery is a complex problem that can occur in every industry sector. This Anti-Slavery Policy (Policy) sets out Atturra’s commitment to identify, reduceand mitigate the risk of modern slavery practices within its supply chain and business operations. This Policy also supports Atturra’s mission to act with integrity to achieve the best outcomes for its clients.

Scope and application

Atturra is a technology advisory services provider operating primarily in Australia, NewZealand and Singapore. This Policy applies to all persons working for, or on behalf of, Atturra in any capacity, including but not limited to employees, directors, officers, agents, contractors, and any third-party representatives.

Meaning of Modern Slavery

Modern slavery refers to any situations of exploitation where a person cannot refuse or leave work because of threats, violence, coercion, abuse of power or deception. The Modern Slavery Act 2018 (Cth) (Act) and divisions 270 and 271 of the Criminal Code 1995 (Cth) prescribe the following practices as conduct that constitutes modern slavery:

  • Human trafficking: the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation
  • Slavery: a person exercises rights and powers of ownership over another including debt bondage, serfdom, servile forms of marriage and exploitation of children.
  • Servitude: where a person does not consider themselves free to cease providing their labour or services or leave their place or area of work because of the use of coercion, threats or deception.
  • Forced labour: all work or service which is exacted from any person who would be subject to a penalty for a failure to work and the work was not offered voluntarily.
  • Debt bondage: a person provides services or offers the services of a third person as security for a real or purported debt and the debt is manifestly excessive, the person’s services are not applied to liquidate the debt or the length and nature of their services are not limited or defined.
  • Forced marriage: a person gets married without freely and fully consenting because they have been coerced, threatened or deceived or because they are incapable of understanding the nature and effect of a marriage ceremony.
  • The worst forms of child labour: work that deprives children of their childhood, their potential and their dignity, and that is harmful to physical and mental development. The term refers to work that is mentally, physically, socially or morally dangerous and harmful to children. In its most extreme forms, child labour involves children being enslaved, separated from their families, exposed to serious hazards and illnesses and/or left to fend for themselves on the streets of large cities.

Atturra’s approach

Atturra is committed to identifying and addressing modern slavery risks within its direct control. Atturra has implemented the following processes and procedures to assist in the detection and prevention of modern slavery risks:

  • Supply chain mapping: Atturra undertakes due diligence in respect of its key suppliers on an ongoing basis to ensure that its suppliers are aligned with Atturra’s policies, codes and values. Supply chain mapping involves categorising suppliers by modern slavery risks associated with several factors, including their geographic location, size and industry.
  • Follow up questionnaire: Atturra requires suppliers identified as “high risk” during the supply chain mapping exercise to complete a modern slavery risk questionnaire to ensure compliance with modern slavery laws and to identify any underlying issues. Significant issues are escalated to senior management.
  • Modern slavery clause: When dealing with external suppliers and third parties, Atturra may negotiate modern slavery provisions in contractual agreements which require counterparties to warrant that they are not aware of any known instances of modern slavery in their supply chain and that they comply with all applicable modern slavery Anti-Slavery Policy 5 Last revised 02/2022 laws. Atturra will only engage with organisations who comply with Atturra’s business standards or those who are taking verifiable steps towards compliance.
  • Training: Awareness of modern slavery risks in the workplace are communicated to employees through written communications and training sessions where applicable. Senior management and procurement personnel briefings are also carried out to raise awareness of modern slavery risks.
  • Reporting:Employees are encouraged to be proactive and report any suspicious activity to their direct manager or supervisor. The Atturra Whistleblower Policy protects and safeguards the confidentiality, wellbeing and career of any individual who asserts any issues that affect the integrity of Atturra’s business operations.
  • Modern slavery statement:Every year that Atturra meets the definition of a “reporting entity” as per the Act, Atturra will prepare and publish a modern slavery statement consistent with the requirements of the Act.

Reporting

Concerns about compliance with this Policy or any other unethical activity should be reported to the employee’s direct manager, supervisor, or human resources advisor. Where it is not appropriate to report to a manager, supervisor, or human resources advisor, a report can be made to the Whistleblower Policy Officer (WPO) via:

 
Email whistleblower@atturra.com
Post The Whistleblower Policy Officer
c/- Atturra Ltd, Level 2, 10 Bond St, Sydney NSW 200
 

Any reports made to the WPO pursuant to this Policy will be responded to in accordance with Atturra’s Whistleblower Policy. A copy of the Whistleblower Policy can be found at https://investors.atturra.com/governance.

 

All reports made will be taken seriously and as such reports must be made in good faith.

 

In Australia, the Australian Federal Police is responsible for investigating suspected cases of modern slavery and can be contacted on 131 237 to discuss or report a suspected case. Contact can be made anonymously.

 

In an emergency and if someone is in immediate danger, please call Triple Zero (000) for police assistance.

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