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Modern Slavery Policy

On Group International Modern Slavery Policy

On Group International acknowledges that modern slavery, in all its forms, represents a grave violation of human rights. This policy outlines our unwavering commitment to respecting human rights and ensuring that modern slavery is absent from both our operations and supply chain. We are dedicated to evaluating, addressing, and mitigating modern slavery risks and impacts in our business and supply chain, with a focus on continuous improvement over time.

This policy applies to all individuals associated with our organization, including employees, directors, officers, labour hire staff, contractors, volunteers, and any other representatives of our organization or entities within our supply chain.

Modern slavery encompasses situations where individuals are exploited through coercion, threats, or deceptive practices, rendering them unable to refuse or leave their employment. It includes serious human rights violations such as human trafficking, slavery and slavery-like practices, bonded or indentured labour, forced labour, forced marriage, deceptive recruitment practices, and the worst forms of child labour. All these practices are illegal in Australia.

Preventing Modern Slavery

On Group International is committed to preventing modern slavery within our operations and supply chains. We regularly assess and address any areas of concern in our business and with our external suppliers. Operating solely in Australia with a small number of employees, all of whom are directly overseen by senior management, the risk of modern slavery in our own operations is minimal. However, we recognize that risks may still exist within our supply chains.

To mitigate these risks, we undertake the following measures:

  • Fair Trade Practices: We prioritize purchasing fair trade certified consumables whenever possible.

  • Due Diligence: We conduct thorough due diligence on third-party providers by obtaining their modern slavery statements or codes of ethics and ensuring they adhere to On Group’s code of conduct.

  • Code of Business Ethics: Our governance policy ensures that On Group International conducts all business activities with the highest ethical and professional standards.

  • Training: New employees receive training on modern slavery as part of their induction, emphasizing their role in identifying potential breaches and understanding their rights and the broader impact of their actions on human rights.

Grievance and Remediation Processes

If anyone covered by this policy has concerns or suspects a breach, they must promptly report it to their immediate supervisor. Concerns raised by subordinates should be reported immediately to the Chief Executive Officer.

Violations of this policy may result in disciplinary action, termination of employment, or referral to relevant authorities.

If a legitimate issue or concern is raised, whether through our grievance process or third-party audit, On Group International will work collaboratively with suppliers, government bodies, worker representatives, and non-profit organizations to address the issue. We are committed to prioritizing the needs of affected individuals and determining appropriate remedies on a case-by-case basis.

Responsibility for Policy, Review, and Implementation

The Chief Executive Officer holds ultimate responsibility and accountability for this policy, including its review and implementation. The Modern Slavery Policy will be reviewed annually or promptly following relevant legislative changes.

Corporate Governance

On Group International Code of Business Ethics Governance Policy on Modern Slavery

1. Introduction

On Group International is dedicated to upholding the highest standards of ethical behaviour and human rights in all aspects of our operations. This Code of Business Ethics Governance Policy on Modern Slavery outlines our commitment to preventing and addressing modern slavery within our organization and supply chain. We are resolute in our efforts to ensure that our business practices and those of our partners are free from all forms of modern slavery.

2. Purpose

The purpose of this policy is to:

  • Define our commitment to preventing modern slavery and human trafficking.

  • Ensure compliance with relevant laws and regulations regarding modern slavery.

  • Provide guidance on identifying and addressing potential modern slavery risks and issues.

  • Promote a culture of transparency and accountability in our operations and supply chain.

 

3. Scope

This policy applies to all individuals and entities associated with On Group International, including:

  • Employees

  • Directors

  • Contractors

  • Labor hire staff

  • Any other representatives of our organization or entities within our supply chain

 

4. Core Principles

4.1 Commitment to Preventing Modern Slavery

On Group International is committed to eliminating all forms of modern slavery, including human trafficking, forced labour, bonded labour, and other slavery-like practices. We will not tolerate such practices within our operations or supply chain.

4.2 Compliance with Laws

We adhere to all applicable laws and regulations related to modern slavery, including the Australian Modern Slavery Act 2018 and other relevant legislation. Compliance with these laws is fundamental to our operations.

4.3 Due Diligence and Risk Assessment

We conduct thorough due diligence and risk assessments to identify and address modern slavery risks within our operations and supply chain. This includes:

  • Evaluating suppliers and partners based on their modern slavery practices and compliance.

  • Implementing contractual obligations requiring suppliers to adhere to our anti-modern slavery standards.

  • Regularly reviewing and updating our risk assessment processes to reflect changes in our operations and supply chain.

 

4.4 Ethical Sourcing

We prioritize ethical sourcing and procurement practices, including:

  • Preferring suppliers that demonstrate a commitment to fair labour practices and modern slavery prevention.

  • Ensuring that procurement decisions consider the potential risk of modern slavery in the supply chain.

 

4.5 Training and Awareness

We provide training and awareness programs to our employees and partners to:

  • Educate them on modern slavery and its implications.

  • Equip them with the knowledge to identify and report any signs of modern slavery.

  • Reinforce our commitment to ethical business practices.

 

5. Reporting and Compliance

 

5.1 Reporting Mechanisms

We have established clear and confidential reporting mechanisms for employees, suppliers, and other stakeholders to report any concerns or suspicions of modern slavery. Reports can be made through:

  • Direct communication with supervisors or managers.

 

5.2 Investigation and Response

All reports of potential modern slavery will be investigated thoroughly and promptly. Appropriate actions will be taken, which may include:

  • Conducting an investigation.

  • Engaging with relevant authorities and organizations.

  • Taking corrective measures to address and prevent further issues.

 

5.3 Disciplinary Action

Any employee or representative found to be involved in or complicit with modern slavery practices will face disciplinary action, which may include termination of employment or contractual relationships and referral to relevant authorities.

 

6. Policy Review and Responsibility

6.1 Chief Executive Officer

The Chief Executive Officer is responsible for the implementation, oversight, and review of this policy. This includes ensuring that adequate resources are allocated to support the policy’s objectives and addressing any modern slavery issues that arise.

6.2 Managers and Supervisors

Managers and supervisors are responsible for enforcing this policy within their teams, ensuring that their staff are trained, and addressing any concerns or violations related to modern slavery.

6.3 Employees and Representatives

All employees and representatives are expected to adhere to this policy, participate in training programs, and report any concerns related to modern slavery.

6.4 Policy Review

This policy will be reviewed annually or as required to ensure its effectiveness and alignment with current laws and best practices. Any amendments will be communicated to all relevant parties.

 

7. Conclusion

On Group International is committed to fostering a business environment free from modern slavery. By adhering to this Code of Business Ethics Governance Policy, we aim to ensure that our operations and supply chain uphold the highest standards of ethical conduct and human rights.

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