Anti-Slavery and Human Trafficking Policy

Classification

Policy Number: FAS201802-1.0 | Version/Last Updated: 1.0 July 2018 | Audience: Public | Commencement: August 2018

Implementation Resources

1.0 Rationale

Sydney Catholic Schools (SCS) is committed to eradicating modern slavery and human trafficking and to:

  • acting ethically and with integrity and transparency in all of its business dealings and relationships; and
  • implementing processes to minimise the occurrence of modern slavery and human trafficking either within its own operations or in any of its supply chains.
  • raising awareness in its offices and school communities of the issue of modern slavery and human trafficking through its social teachings.

“Therefore, we declare on each and every one of our creeds that modern slavery, in terms of human trafficking, forced labour and prostitution, and organ trafficking, is a crime against humanity. Its victims are from all walks of life, but are most frequently among the poorest and most vulnerable of our brothers and sisters. On behalf of all of them, our communities of faith are called to reject, without exception, any systematic deprivation of individual freedom for the purposes of personal or commercial exploitation; in their name, we make this declaration.”

Pope Francis — Declaration on International Day for the Abolition of Slavery, 2 December, 2014

2.0 Guiding Principles
2.1

SCS is working toward eradicating modern slavery in its own operations and supply chains and expects the same commitment from its staff and Suppliers.

2.2

Eradicating modern slavery requires constant vigilance given the issue can manifest itself in a number of ways including poor working standards, and payment of under award wages.

2.3

Given the possible cross-cultural impact of this policy, SCS looks to change behaviours gradually through co-operation, vigilance and education.

3.0 Policy
3.1

SCS commits to eliminating slavery and human trafficking within its supply chains and operations as soon as reasonably possible.

3.2

This policy will apply to all SCS staff, and Suppliers including their employees, agents, volunteers, contractors, consultants and business partners.

3.3

Due to the hidden nature of modern slavery, confidence in its removal from SCS supply chains and its operations will develop incrementally and higher costs may result from implementation.

3.4

Suppliers tendering for SCS contracts will be required to certify to SCS their compliance with a SCS Code of Practice, which requires them to:

  • implement a policy within their workplace committing to 12 anti-slavery principles (Appendix F);
  • establish a process to monitor compliance with the anti-slavery principles;
  • take action to remediate any breaches they are found to have committed.
3.5

Suppliers with total turnover of more than $50m per annum will be requested to certify to SCS their compliance with a requirement of the NSW Modern Slavery Bill 2018 namely that they have released a statement as to modern slavery, which complies with section 3 of that Bill (Appendix B).

3.6

Suppliers with turnover of less than $50m per annum will be requested to annually certify to SCS their compliance with the Catholic Archdiocese of Sydney’s Guide for Business Practice (Appendix C).

3.7

SCS may at its discretion give preference in future works and orders to Suppliers who can demonstrate compliance with this policy.

4.0 Procedures
4.1

Responsibilities of Sydney Catholic Schools

4.1.1

Oversee implementation, compliance with and reporting on the Policy.

4.1.2

Educate staff and students as to the policy, its breadth and methods for implementation.

4.2

Responsibilities of Suppliers

4.2.1

When tendering for SCS contracts certify that they do comply or are implementing processes so as to comply with SCS’ Code of Practice; or

4.2.2

For the term of the relevant contract with SCS certify that they will comply with the Catholic Archdiocese’ of Sydney Guide for Business Practice as set out at Appendix C.

4.3

Responsibilities of the Directorate of System Stewardship

4.3.1

Identify key risk areas within SCS’ supply chains where non-compliance is more likely and take measures to ensure compliance.

4.3.2

Monitor supplier compliance with the Archdiocese of Sydney’s Guide to Business Practice, SCS’ Supplier’s Code of Practice or the NSW Modern Slavery Bill 2018.

4.3.3

Educate Suppliers, staff and students as to the policy, its breadth and methods for implementation.

4.3.4

In consultation with SCS Legal, monitor developments in the laws concerning modern slavery.

4.4

Responsibilities of Principals

4.4.1

Familiarise himself/herself with this policy and SCS’ Code of Practice, consider the potential reach of the policy.

4.4.2

Educate teaching and office staff as to the implications and intended method of implementation of this policy.

4.5

Responsibilities of all Staff

4.5.1

Familiarise himself/herself with this policy, consider the potential reach of the policy

4.6

Responsibilities of the Religious Education and Evangelisation Directorate

4.6.1

Educate staff of the issues of modern slavery and human trafficking providing expertise and resources to assist school communities in raising awareness of the issue. This is consistent with the teachings of the Catholic Church.

“There exist also sinful inequalities that affect millions of men and women. These are in open contradiction of the Gospel: Their equal dignity as persons demands that we strive for fairer and more humane conditions. Excessive economic and social disparity between individuals and peoples of the one human race is a source of scandal and militates against social justice, equity, human dignity, as well as social and international peace.”

(Catechism of the Catholic Church no.1938)

4.6.2

Ensure that the Anti slavery initiative is supported through school
and system events and celebrations.

4.6.3

Provide resources and support documents to support the inclusion
of Anti slavery initiative into the Religious Education Curriculum and other subjects and Key Learning Areas, as appropriate.

5.0 Bases of Discretion
5.1

SCS may at its discretion choose to not contract with suppliers who cannot satisfy its policy requirements.

6.0 Explanatory Notes and Definitions
6.1

Modern Slavery

Includes any practice constituting a modern slavery offence (see Appendix D) and any practice involving the use of any form of slavery, servitude or forced labour to exploit children or other persons taking place in the supply chains of SCS.

6.2

Supplier

Means a party including their employees, agents, volunteers, contractors, consultants and business partners that supplies goods or services to Sydney Catholic Schools Ltd at Sydney Catholic Schools Trust in accordance with a written agreement between the two.

7.0 Supporting Documents
7.1

Related policies

  • Financial Stewardship Policy (internal)
  • Procurement Policy (internal)
7.2

Supporting documents

8.0 Appendices
8.1

Appendix A: Supplier Code of Practice (for tenderers to SCS)

8.2

Appendix B: Supplier self-certification as to compliance with the NSW Modern Slavery Bill 2018 (for Suppliers with an annual turnover of more than $50m).

8.3

Appendix C: Supplier self-certification as to compliance with Archdiocesan Guide to Business Practice (for Suppliers with an Annual turnover of less than $50m).

8.4

Appendix D: Practices constituting a modern slavery offence -Schedule 3 Offences – NSW Modern Slavery Bill 2018

8.5

Appendix E: Catholic Archdiocese of Sydney’s Guide for Business Practice

8.6

Appendix F: 12 Supplier Guiding Principles to minimising slavery in the workplace

9.0 Classification
9.1

Policy Number:FAS201802-1.0

9.2

Version: 1.0

Last modified: July 2018

This policy supersedes all previous policies relating to matters contained therein. In so much as any aspect of this policy may appear to be in conflict with another Archdiocesan system or school-based policy, then precedence is to be given to this policy.

9.3

Audience: Public

9.4

Review by: June 2019

Changing Laws, legal precedents and experience may all serve as triggers for immediate review.

9.5

Approved by Leadership Team: 14 June 2018

9.6

Endorsed by SCS Board: 27 June 2018

9.7

Approved by Executive Director of Sydney Catholic Schools: 5 July 2018

9.8

Commencement Date: 1 August 2018

Related Policies

  • Financial Stewardship Policy (internal)
  • Procurement Policy (internal)

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