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.