Purpose

Ferrycarrig Construction recognises the importance of a safe work environment which actively promotes best practice. This Policy supports the intent of international conventions, treaties and protocols relevant to combatting modern slavery and the Modern Slavery Act (Cth) 2018.

It is consistent with our Ethical Framework, that expects a culture of high ethical standards, including compliance with applicable laws, contractual and other obligations.

Scope

This policy applies to all Employees of Ferrycarrig Construction Pty Ltd Inc. all persons performing work at the direction of, in connection with or on behalf of Ferrycarrig Construction (for example, contractors, subcontractors, agents, consultants and temporary staff) (collectively ‘workplace participants’).

Our Position on Modern Slavery

We are committed to conducting business responsibly and ethically and to ensuring that all aspects of our business practices, including our suppliers and subcontractors, are free from any form of slavery. We refute all forms of modern slavery which can take the form of unpaid or underpaid servitude, human trafficking and forced labour. We are committed to implementing effective onboarding systems and controls to ensure that it does not take place within our own business or through any of our suppliers and subcontractors.

We have a firm stance that any infractions of our position on Modern Slavery or the like will firstly attempt remediation, if possible, to stamp out any kind of modern slavery within our business, suppliers or any other service providers. Where remediation is not possible or deliberate onboarding, use or where it is proven there is known Modern Slavery breaches are occurring within our business, suppliers, subcontractors or other service providers will lead to immediate termination of contract and/or employment.

Our Remediation Processes

Our company believes that in order to combat modern slavery, prevention is the best form of remedy. However, prevention is not always possible and therefore need to provide access and opportunity to remediation where the following points and actions will act as a program of remediation for our company:

We will ensure that our company or the suspected/proven company in breach will:

• Allow access to which issues can be raised confidentially by phone, email or in writing to either: a workforce helpline; an independent specialist helpline service; a Senior Manager or our HR Department who is separate to the direct supervision of the worker.
• Demonstrate that workers, supervisors and managers can confidentially raise issues of concern to a member of the senior team without fear of retribution
• Demonstrate that complaints/ grievance procedures are in place, issued to all affected workers and operated fairly and independently.
• Verify that we or the providers have completed the complaints/ grievance procedure implicitly and was operated fairly and independently with corrective actions put into place.
• Verify that the corrective actions have been closed out and that the breach has been completely remediated.
• Ensuring We Perform Our Due Diligence

We assess the risk of modern slavery taking place in our business by identifying and managing any areas of concern within our business operations and any external suppliers.

As a construction company, operating in east coast Australia, there is very little risk of modern slavery occurring within our direct business operations.

However, we acknowledge that we could be indirectly exposed to the risk of modern slavery and human trafficking through our suppliers and/or subcontractors.

Due to the nature of our business, we do not make use of high-risk suppliers or subcontractors, which are susceptible to modern slavery risks. We have taken the following actions to manage that risk:

• Purchasing, where possible products through reputable suppliers within Australia;
• Conducting due diligence on third party service providers through our onboarding processes; and
• Partnering with suppliers and subcontractors who share our stance on modern slavery.

We are committed to undertaking our due diligence processes when contracting with external suppliers and subcontractors and to identifying and assessing any indications of suppliers or subcontractors being of high risk.

We will not work with high-risk suppliers or subcontractors unless we have conducted the appropriate onboarding assessment that our stance on modern slavery will not be compromised.

Commitment

The policy sets out the standards that we expect all of our suppliers to comply with when producing and supplying products for Ferrycarrig, no matter where they operate in the world.

We recognise that full compliance with these criteria may take time for some suppliers and subcontractors, and we are committed to working with our suppliers and subcontractors to implement improvement plans and help them achieve compliance.

Ferrycarrig reserves the right to cease business with suppliers that do not meet the minimum ethical standards.

Ferrycarrig commitment is to:

• Ensure the risk of modern slavery practices within the business operations is understood and addressed in accordance with internationally recognised principles and the Modern Slavery Act 2018
• Eliminate the potential for modern slavery practices in our operations and supply chain
• Ensure transparency with our employees, clients, suppliers and stakeholders regarding the process, along with our commitment and intent
• Develop a plan to measure the effectiveness of the approach taken to address the risks associated with modern slavery.
• We are committed to training our employees and ensuring they have a strong understanding and respect for how their choices can have far-reaching impacts upon basic human rights across the world. We have made the training resources provided by Anti-Slavery Australia available to our staff.
• We will continue to identify and evaluate risks relating to human rights and develop our policies, procedures, and training to help neutralise modern slavery.

Supply chain

Ferrycarrig sources a wide range of goods and services across our projects. Ferrycarrig places a high level of importance on the behaviour of our total supply chain as we believe this is where we can make a major impact. Ferrycarrig promotes the protection of its employees and the environment.

Ferrycarrig has employment policies, processes, procedures, and guidelines that reflect current legislation and best practice to safeguard the interests of employees, potential employees and others working for us. Training is designed by our HR Team and includes compulsory staff induction and ongoing training on key internal policies and procedures.

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of the Ferrycarrig supply chain constitutes any of the various forms of Modern Slavery, your query should be raised with your manager and the HR Team.

Ferrycarrig considers that it has a low risk of modern slavery in the employment or engagement of our employees given:

• The entirety of our direct workforce is located in Australia, which has one of the lowest modern slavery estimated prevalence scores globally.
• Minimum entitlements for employees meet or exceed the National Employment Standards as set out in the Fair Work Act 2009 or where a Modern Award applies
• While most of our suppliers are
• headquartered in Australia, where possible, we have identified the countries where those goods and services are produced or sourced from, to appropriately assess the modern slavery risks.

Reporting

Internal reporting is critical to the success of this policy, and it is both expected and valued. You are required to be proactive and promptly report any suspected violations of the Policy or any illegal or unethical behaviour that you become aware of.  If you believe that a breach of this Policy has occurred or is likely to occur, you must notify your manager and/or the HR team.

Ferrycarrig aims to encourage openness and will support anyone who raises genuine concerns in good faith under this Policy, even if those concerns turn out to be mistaken. Ferrycarrig is committed to ensuring staff do not suffer any detrimental treatment as a result of reporting in good faith their suspicion that Modern Slavery of whatever form is or may be taking place in any part of our business or in any of our supply chain.