Global Ethical Sourcing and Modern Slavery Policy

Global Ethical Sourcing and Modern Slavery Policy


1. What We Require of Our Suppliers

Zero Tolerance on slavery, forced or bonded labour & No Human trafficking.

Suppliers must not use forced labour (slave, prison, indentured, bonded, or otherwise). Suppliers must not traffic workers. Suppliers must not exploit their workers by means of threat, force, coercion, abduction, or fraud. Working must be voluntary, and workers must be free to leave work and terminate their employment with reasonable notice. Workers shall not be required to pay recruitment, hiring, or other similar fees related to their employment and that shall be communicated to workers in their native language in advance of employment. Worker employment terms must be clear and understandable.

Our suppliers must not require their workers to surrender government issued identification, passports, or work permits as a condition of working, and our suppliers may only temporarily hold onto such documents to the extent reasonably necessary to complete legitimate administrative and immigration processing.

Suppliers must ensure that labour sourcing or recruiting organisations they engage with also comply with these requirements.

No child labour

Suppliers must only engage workers whose age is the greater of: (i) 18, (ii) the age of completion of compulsory education, or (iii) the minimum age to work in the country where work is performed. Furthermore, workers under the age of 18 must not perform work which is hazardous.

Suppliers must ensure that any work by a child or young person is not likely to interfere with that person’s education, or to be harmful to that person’s health or mental, spiritual, moral or social development.

In some jurisdictions, children and young people may be offered the opportunity for work-experience, to participate in research or other short-term apprenticeships which are consistent with local laws.

Employment terms, wages and record keeping

If a Supplier engages a worker, those Suppliers must comply, at a minimum, with all laws regulating local wages, overtime compensation and legally mandated benefits. Record keeping must be accurate. Such workers must be provided with written and understandable information about their pay and employment conditions. Deductions from wages, unless provided by law, shall not occur without the agreement of the worker concerned.

Working hours

Where Supplier engage workers, 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 international 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 or harassment

Suppliers must ensure that all conditions of employment must be based on an individual’s ability to do the job, not on the basis of characteristics, such as gender, ethnic origin, religion, age, disability, personal beliefs, marital status, sexual orientation, union membership or political affiliation. Certain projects may require participants have certain characteristics (eg. a voice sample may be required of people from various age groups as voice patterns and pitch change throughout life).

Workers shall be treated with dignity and respect. Suppliers must ensure that they provide an environment where their employees can work without distress or interference caused by harassment, discrimination, bullying or any other inappropriate workplace behaviour.

Working conditions

Suppliers shall provide a safe and hygienic working environment for their workers (including supplier provided worker accommodation) that is without risk to health and without any unreasonable hazards. Workers have the right to refuse work that is unsafe.

No bribery. Act ethically

Suppliers must act ethically and comply with relevant anti-corruption laws. 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.


Where sub-contracting is permitted, suppliers must have adequate processes in place for properly managing sub-contracting to ensure that sub-contractors operate in accordance with these requirements.

Environmental compliance

Suppliers shall comply with relevant local and national environmental protection laws and will as far as practicable comply with applicable international environmental protection standards.

Freedom of association

Suppliers shall respect the rights of their workers to lawfully associate or not to associate with worker groups or trade unions of their choosing, as long as such groups are legal in the country of operation. Where provided for under local law, workers are allowed to select worker representatives and those representatives will not be discriminated against.

Migrant workers

Migrant workers shall have the same entitlements as local workers as stipulated by local law. If suppliers engage foreign or migrant workers, such workers must be engaged in full compliance with the immigration and labour laws of the host country.

Grievances and Whistleblower Protections

Suppliers must have a process to allow their workers to raise grievances. Suppliers must protect worker whistleblower confidentiality and prohibit retaliation against workers who report workplace grievances.


2. Modern Slavery Risk Management Guidelines for New Age Promotions

Risk Owner

New Age Promotions PTY LTD will appoint a risk-owner with accountability for modern slavery issues and compliance with this Policy. The risk owner will be accountable for addressing modern slavery issues in company operations and with supplier relationships.

Supply chain mapping and risk assessment

New Age Promotions PTY LTD will map supply chains it manages and assess the risks of modern slavery across its operations and the modern slavery risks of those suppliers.

On-boarding and contracting

New Age Promotions PTY LTD will seek assurances from or perform due diligence on new (or renewing) suppliers to determine their risk in relation to ethical sourcing and modern slavery. New Age Promotions PTY LTD will have a process in place to consider the supplier’s reported ethical sourcing and modern slavery performance.

Audit and compliance program

New Age Promotions PTY LTD will assess these processes through their audit/compliance program to confirm compliance with this Policy.


During the time leading up to the first required Modern Slavery Statement, New Age Promotions PTY LTD will train its workers in relation to the Policy and ensure they receive training on any supporting processes applicable to their role.

Complaints mechanism. Whistleblowers.

New Age Promotions PTY LTD will implement a reporting mechanism for concerns in relation to modern slavery which allows for confidential and anonymous reporting and provides protection from reprisal. Concerns which are reported will be investigated and reported back to the company directors.


New Age Promotions PTY LTD and its suppliers must be committed to remediate any breaches of this Policy, mitigate risks and constantly improve processes.


New Age Promotions PTY LTD will monitor and review the effectiveness of this Policy and the risk management measures described above at the end of each calendar year.


New Age Promotions

18/135 Cardigan St Carlton 3053

Ph: +613 9937 2121

Fax: +613 9937 2120

[email protected]