Introduction

Modern slavery encompasses a range of exploitative practices, including slavery, human trafficking, servitude, forced labour, and debt bondage. Elker acknowledges that businesses play a vital role in combating modern slavery and accepts this as a key corporate responsibility. We recognise the complexity of modern slavery and are committed to collective action, commitment, and accountability to eradicate it. This policy is part of our strategy to work with stakeholders and suppliers to achieve the shared goal of eliminating modern slavery.

Our commitment

Elker is dedicated to implementing controls to help eradicate modern slavery within our business by managing risks and raising awareness of this issue within our operations and supply chains.

1. Policy application

This policy applies to anyone working for, on behalf of, or doing business with Elker, including all suppliers, employees, officers, contractors, sub-contractors, and consultants. We expect all parties with a business relationship with us to familiarise themselves with this policy and act consistently with its values. Elker also requires all suppliers to take verifiable steps to comply with this policy.

This policy should be read in conjunction with Elker's Whistleblowing Policy, which supports ethical practices and provides avenues for reporting concerns.

Expectations of our business partners

Elker expects all service providers, suppliers, and contractors to share our commitment to lawful and ethical conduct, ensuring that modern slavery is not present within their organisations or supply chains.

2. Key definitions

Modern slavery

Modern slavery includes situations where coercion, threats, or deception are used to exploit individuals and undermine their freedom. These practices, whether explicit or implicit, are defined in the Modern Slavery Act 2018 (Cth) (‘Act’) and encompass:

trafficking in persons
slavery
servitude
forced labour
forced marriage
debt bondage
deceptive recruiting for labour or services

The worst forms of child labour refer to extreme exploitation of children, including enslavement or exposure to hazardous work.

3. Important commitments

Staff and contractor engagement: All staff and contractor engagements must be approved by the Head of People and Culture, including an assessment of modern slavery risks.

Workplace standards: Elker strives to ensure that no staff members are subjected to modern slavery practices. We comply with Australian workplace laws, which cover employment conditions, safety, and ethical standards, and foster an inclusive, respectful, and discrimination-free work environment.

4. Supply chain expectations

Elker understands that global supply chains can increase modern slavery risks, particularly where recruitment practices are less visible. To help mitigate this risk, we require our suppliers to:

avoid using any form of forced, bonded, or indentured labour;
comply with the minimum legal working age in the country of operation, or, where absent, the standards set by the International Labour Organization (ILO) Convention 138;
adhere to local laws regarding wages and legally mandated benefits;
respect working hours as regulated by local law;
treat workers with dignity and respect, ensuring a workplace free from discrimination, harassment, and offensive or hostile behaviours; and
provide a safe, hygienic working environment that mitigates health risks, taking industry-specific hazards into account.

Elker’s supply chain measures

All supplier contracts include clauses addressing modern slavery risks.

A reporting portal on our website linked to whistleblowing allows for anonymous or named submissions of any concerns regarding modern slavery.

5. Consequences of policy breach

If any individual or entity to whom this policy applies fails to comply with its terms, Elker will take appropriate action, which may include disciplinary measures (for employees) or termination of contracts (for contractors or suppliers).

In cases where modern slavery is suspected or identified within a supplier’s operations, Elker may:

take further steps to verify if modern slavery is occurring;
consult industry experts or relevant authorities;
collaborate with local and international organisations;
involve law enforcement if needed; and
address structural factors contributing to modern slavery or, if necessary, terminate relationships with non-compliant entities.

6. Reporting modern slavery concerns

Elker encourages all employees and stakeholders to report concerns about modern slavery in our organisation or supply chain. The platform is managed by Resolve Advisors, with external contacts who are independent of Elker. The platform can be accessed here.

Elker allows you to:

Report anonymously or with a name

Once you start your report, you can upload files, save it as a draft to complete later and submit it whenever you are ready.

Chat safely

Once your report is submitted, you can chat with your chosen contact, whether anonymous or named. The respondent will provide support and advice on the platform.

If you report anonymously, please save your secure access key - this lets you follow up and provide any additional information needed to resolve your concern.

Even if your matter doesn't qualify as whistleblowing, our contacts will guide you to an appropriate pathway.

7. Jurisdiction and legal compliance

Under Australian law, modern slavery is defined by the Modern Slavery Act 2018 (Cth) (‘Act’). In cases of any inconsistency, the definitions in the Act will take precedence over this policy.

Date reviewed: August 2024

Policy Owner: Shirli Kirschner - Director

Policy review: Annually

Anti-Modern Slavery Policy Statement