Ethical Sourcing and Modern Slavery Policy

Effective: August 30th, 2019.

Thank you for visiting ittos.studying.be, an online service managed by Peter Caffin, located in Perth, Western Australia.

All businesses, large and small, including little online web apps like this one, play an important role in respecting and promoting human rights and eradicating modern slavery. While slavery plays little part in the Australian IT industry directly, we all have the responsibility to ensure this practice does not play a part in the business of our suppliers.

This policy is based, with thanks, on the Wesfarmers Ethical Sourcing and Modern Slavery Policy, with some minor adaptions made to suit our differing business types.

Commitment

The purpose of this Policy is to ensure that we:

are compliant with local, national and other applicable laws and regulations in the areas in which the businesses operate;
source products and services in accordance with legal obligations and community expectations while working with suppliers to improve their social and environmental practices;
act to prevent, mitigate and where appropriate, remedy modern slavery in their operations and supply chains
undertake to avoid business dealings with companies and organisations that engage in shameful but legal government endorsed quasi-slavery activities, such as hosting Work For The Dole placements and PaTH Internships, which would otherwise qualify as forced labour and false apprenticeship schemes.

If the policy is breached, we will act as quickly as practicable to remedy our adverse impacts and engage directly with affected stakeholders.

Minimum Standards expected of suppliers

No forced or bonded labour	Employment shall be freely chosen. Suppliers shall: not use any type of forced labour (any work or service extracted from any person under the menace of any penalty, which work has not been freely chosen by the person), bonded labour (work which is not for compensation received by the worker, but to repay a debt, which is often incurred by another person offering the worker's labour in exchange) or indentured labour (in which an employer forbids workers from leaving employment at the worker's discretion); respect the freedom of movement of their workers and not restrict their movement by controlling identity papers, holding money deposits or taking any other action to prevent workers from terminating their employment; and ensure that workers are free to leave their employer after reasonable notice.
No child labour	Suppliers shall comply with the minimum legal working age in the country in question or in the absence of such law, by the International Labour Organisation (ILO) Convention 138. Suppliers must be able to verify the age of all employees to ensure compliance. Suppliers must accept the principles of remediation6 of child and under age workers, and where such labour is discovered suppliers must establish and implement appropriate remediation for such workers and introduce effective systems to prevent the use of child labour in the future. "Child labour" is defined as any work by a child or young person, which does not comply with the provisions of the relevant ILO standards, and any work that is likely to interfere with that person's education, or to be harmful to that person's health or mental, spiritual, moral or social development. "Child (or Children)" is defined as a person under the age of 15, or below the age at which school attendance is not compulsory under local law, whichever is older. "Young Person" is defined as a person under the age of 18 but not classified as a child.
Wages, benefits, and transparent record keeping	Suppliers must comply at a minimum with all laws regulating local wages, overtime compensation and legally mandated benefits. Record keeping must be accurate and transparent. Workers must be provided with written and understandable information about their employment conditions before they enter employment and about their wages for each pay period. Deductions from wages for disciplinary measures or any deductions from wages not provided for by law shall not occur without the express permission of the worker concerned. All disciplinary measures should be recorded.
Working hours	Working hours must comply with applicable local laws. Workers should not be required to work more than the maximum hours per week as stipulated by local laws or in the absence of such law by the applicable ILO convention. Overtime shall be agreed, shall not be excessive, shall not be requested on a regular basis and shall be compensated as prescribed by applicable local laws.
No discrimination	All conditions of employment must be based on an individual's ability to do the job, not on the basis of personal characteristics, such as gender, ethnic origin, religion, age, disability, personal beliefs, marital status, sexual orientation, union membership or political affiliation. Suppliers must ensure that they provide an environment where their employees can work without distress or interference caused by harassment, discrimination or any other inappropriate workplace behaviour.
No harassment or abuse	Workers shall be treated with dignity and respect. In particular, suppliers will provide a workplace free from harassment, including physical, sexual, verbal or visual behaviour that creates an offensive, hostile or intimidating environment.
Freedom of association, grievance mechanisms and recourse	Suppliers shall respect the rights of workers to lawfully associate or not to associate with groups of their choosing, as long as such groups are legal in the country of operation. Workers should have the right to join or form trade unions of their choosing. Suppliers should not interfere with, obstruct or prevent legitimate related activities, such as collective bargaining. Workers are allowed to select worker representatives. Representatives should not be discriminated against and should have regular access to company management or appropriate process in order to address grievances and other issues. Suppliers must have a policy in place for workers to approach management on issues of concern, on their own or through worker representatives, confidentially.
Working conditions	Suppliers shall provide a safe and hygienic working environment that is without risk to health, taking into consideration knowledge of the relevant industry and any specific hazards. Workers shall receive adequate and regular training to perform their jobs in a safe manner. Personal protective equipment and machinery safeguards shall be supplied and workers trained in their use. Where suppliers provide accommodation it shall be clean, safe and meet the basic needs of workers. Workers will have access to clean toilet facilities, clean drinking water and, where appropriate, sanitary facilities for food storage and preparation. Workers have the right to refuse work that is unsafe.
No bribery	Bribes, favours, benefits or other similar unlawful or improper payments, in cash or in kind, are strictly prohibited, whether given to obtain business or otherwise. Suppliers shall keep accurate records of all payments made and received in cash or in kind, for audit purposes. Sub-contracting Where sub-contracting is permitted, suppliers must have adequate processes in place for properly managing sub-contracting to ensure that subcontractors operate in accordance with this and any applicable divisional/business unit policy, and is undertaken strictly in accordance with the contract.
Environmental compliance	Suppliers shall comply with relevant local and national environmental protection laws and will as far as practicable comply with international environmental protection standards.
Animal welfare	Suppliers must ensure animals are treated humanely and with respect.
Migrant workers	Migrant workers shall have the same entitlements as local workers as stipulated by local law. Any commissions and other fees in connection with employment of migrant workers must be covered by the employer. The employer must not require the worker to surrender identification documents. Workers employed through a third party agent or contractors are the responsibility of the suppliers, and are thus covered by these Minimum Standards.
Hiring and regular employment	Suppliers must provide each worker with a clear, understandable labour contract containing all legally required employment terms, entitlements and conditions. In addition, where possible, suppliers should work towards providing permanent employment for workers and avoid labour-only contracting arrangements, consecutive short-term contracts, excessive piece-work or false apprenticeship schemes to avoid obligations of regular employment to workers.

Modern slavery risk management

Accountability for modern slavery issues, with an identified risk owner	Divisions/business units acknowledge that they are accountable for addressing modern slavery issues in operations and supplier contracts, and will nominate a specified individual or role to be responsible for co-ordinating management of this risk.
Supply chain mapping and risk assessment	Divisions/business units must assess the risks of modern slavery across their operations. The risk assessment must initially address the modern slavery risks of tier 1 suppliers and then assess those suppliers beyond tier 1 who are determined by the division/business unit to be high risk.
On-boarding and contracting	Divisions/business units must perform due diligence on new suppliers to determine their risk level and control procedures in relation to ethical sourcing and modern slavery as appropriate for its business. The division/business unit must have a process in place to consider the supplier's ethical sourcing and modern slavery performance during the supplier on-boarding.
Complaints mechanism	Divisions/business units must have an accessible and well-publicised reporting mechanism for concerns or disclosure in relation to modern slavery which allows for confidential and anonymous reporting and provides protection from reprisal. There must be clear processes for investigating and reporting on the issues raised through the reporting mechanism. Remediation Divisions/business units must be committed to working with suppliers to remediate any breaches of this policy.
Stakeholder engagement	Divisions/business units must have an approach to stakeholder engagement in place.
Review	Divisions/business units must monitor and review the effectiveness of the risk management measures described above.

Modifications

We may amend this Policy at any time by posting the amended version on the website.

Contact us

Alternatively, you can write to us at:

ittos.studying.be Administrator
PO Box 36
Dianella WA 6059
AUSTRALIA