Symmetry Human Resources conducts its business in compliance with the law, including all applicable modern slavery laws, initiatives and guidelines. It takes a zero tolerance approach to modern slavery within its operations and supply chains.
Accordingly, Symmetry Human Resources has adopted this policy to support human rights and circumvent modern slavery activities to the extent possible.
This policy is intended to outline Symmetry Human Resources’ commitment to identify, prevent, mitigate and account for modern slavery risks or practices, and further to set out clear standards of conduct regarding responsibilities and reporting.
It applies to all employees (existing and prospective) acting for or on behalf of Symmetry Human Resources at all levels and includes permanent, fixed-term or temporary employees, directors, executives, officers, consultants, secondees, contractors and agents.
1. What is Modern Slavery?
Modern slavery is a term used to describe a range of serious exploitation practices. Practices that constitute modern slavery can include:
More generally, modern slavery may include circumstances where a person’s freedom and ability to make choices has been significantly undermined or removed.
2. Types of modern slavery
Modern slavery can take many forms and some of them are often subtle and hard to identify. Below are some key types of modern slavery exploitation.
Child labour is the exploitation of children through any form of work that deprives them of their childhood, their potential, and their dignity.
Debt-bondage is work exchanged for a debt for no wages, or less than that required by law. Bonded labourers may be subjected to different forms of abuse, including long working hours, physical and psychological abuse, and violence.
Deceptive recruiting for labour or services are situations where a person is deceived into entering an engagement to provide labour or services for minimal pay, or which they cannot leave because they have been manipulated into a debt.
Forced labour is any compulsory labour that occurs, under threat of punishment. Almost all modern slavery practises contain some element of forced labour.
Servitude occurs when the person does not consider themselves free to cease providing their labour or services.
Slavery involves the exercise of power of ownership over a person, including the power to make them an object of purchase and use their labour in an unrestricted manner.
3. Who is most at risk of modern slavery?
Modern slavery is widespread across vulnerable groups of individuals, including for example:
4. Identifying risks of modern slavery
Awareness of modern slavery is instrumental in mitigating against the risks of its existence in our organisation and supply chains, through identification and reporting. Some common signs of modern slavery or exploitation can include:
Excessively low prices and fast turnaround when compared with other suppliers.
Suspicious payments to third parties that appear to be unusual, such as a personal obligation to pay a third-party recruitment firm upon being awarded a job.
Inappropriate identification documents including for example right to work authorisations, or information relating to a person’s identify is withheld or false.
Inadequate work health and safety standards for facilities, training, and policies. Or alternatively, if you are informed of poor living conditions or situations where staff feel unsafe, or that they are subject to unlawful workplace incidents such as bullying, harassment and discrimination.
Undisclosed subcontracted work that has limited process, or is lacking documentation, which affects visibility over the supply chain.
5. Responsibilities
Symmetry Human Resources takes a zero-tolerance approach to all forms of modern slavery and is strongly committed to delivering accountability and transparency to all clients and stakeholders.
Symmetry Human Resources also understands general obligations with respect to modern slavery and is committed to ensuring compliance with relevant legislative and regulatory requirements, including that it protects people who disclose such unlawful behaviour from victimisation.
Accordingly, in seeking to encourage ethical business practices and to prevent modern slavery activities to the extent possible, the following warranties are made:
Further, it is the responsibility of every person to help detect, prevent and report instances of modern slavery or concerns they may have in relation to modern slavery including by complying with this policy, and avoiding any activity that might lead to, or suggest, a breach of this policy.
6. How to raise a concern
To the maximum extent practicable, a person who genuinely discloses an allegation or concern about modern slavery in breach of this policy, a law or other standard of behaviour (“Whistleblower”) will be protected from any adverse action for having raised such allegations or concerns, even where they prove to be unsubstantiated or incorrect. Except that, a person who maliciously or vexatiously makes a disclosure or false allegations may be subject to disciplinary action.
This protection also applies to employees who participate or assist in an investigation concerning modern slavery.
Reasonable grounds
Before making a disclosure, you must have reasonable grounds to suspect the relevant conduct has occurred or is happening.
Accordingly, all disclosures should provide specific, adequate and pertinent information with respect to, among other things, dates, places, persons, witnesses and the like, to enable a reasonable investigation to be conducted.
However, whistleblowing does not give you immunity from disciplinary or legal actions if found guilty of the same or similar misconduct.
Workplace policy
For your own benefit, it is important that you do not ‘blow the whistle’ on any conduct before understanding your rights and obligations as a Whistleblower. You may not be protected by law if your allegation or concerns are not about reportable conduct that is protected.
Accordingly, you are encouraged to speak with an authorised Whistleblower Protection Officer, a senior manager or director.
Symmetry Human Resources recognises that maintaining appropriate confidentiality is crucial in ensuring that potential Whistleblowers make disclosures of modern slavery in an open and timely manner, and without fear of reprisal.
Accordingly, Symmetry Human Resources will take all reasonable steps to protect the identity of the Whistleblower and will adhere to any statutory requirements in respect of the confidentiality of disclosures made. However, in appropriate cases, disclosure of the identity of the Whistleblower, or the allegation made by them, may be unavoidable.
Compliance
It is your responsibility to understand and comply with this policy. You will not be excused for any breach of this policy because you were instructed or influenced to act in a way that constitutes a breach of this policy. Ignorance will not be accepted as justification for a breach.
If there is an alleged breach of this policy, it may be investigated. If an investigation discloses that a breach is substantiated, disciplinary action may be taken, which may include a formal warning, suspension, reassignment or demotion, or termination of employment.
Last Reviewed: December 2024