Insight Modern Slavery Policy

Approval Date: March 2023
Review Date: February 2025
Review By: Directors

Background
Modern slavery is defined as when an individual is exploited by others, for personal or commercial gain. Whether tricked, coerced, or forced and they lose their freedom. This includes but is not limited to human trafficking, forced labour and debt bondage. (AntiSlavery International) To help combat modern slavery the Australian Federal Government passed “The Modern Slavery Act” in 2018. This Act requires entities based, or operating, in Australia, which have an annual consolidated revenue of more than $100 million, to report annually on the risks of modern slavery in their operations and supply chains, and actions to address those risks. Other entities based, or operating, in Australia may report voluntarily. (Dept. Home Affairs) .

Policy
Insight supports efforts to reduce the impact of modern slavery and will adopt some of the requirements of the Australian legislation on a voluntary basis. Wherever possible A preference will be given to suppliers that have implemented strong modern slavery risk mitigation programs.
Implementation

Managing Supply Chains
Our suppliers include vendors of IT and communications equipment and services; office cleaning and other facilities management services; transport such as airlines and couriers; marketing such as merchandise suppliers; hotels and conference providers; office equipment and supplies; and professional services such as auditors, accountants, consultants, legal counsel, banks, insurers, and medical services providers. The suppliers are primarily domiciled in Australia, but also include some global entities.
Suppliers of IT equipment, office equipment, corporate merchandise, courier services and travel services are considered to have an elevated risk of modern slavery in their supply chain. Insight will identify suppliers who have prepared annual modern slavery risk assessments and will review those reports. Other suppliers will be asked to complete a questionnaire to help us to understand how vulnerable their supply chains may be. Suppliers assessed to have an elevated risk will be reviewed by COO and Directors to assess this risk and the appropriateness of continual use of this supply chain.

Staff Education
Insight is committed to training staff about the risks of modern slavery and how to assess suppliers of goods and services. Training is initially provided through Insight staff meeting, with new staff receiving training from the COO. A guide to evaluating suppliers will be made available to all staff.

Record keeping
Records will be kept by the CFO of all supplier assessments and the related risk assessments. A record will also be kept of any training provided to staff.

Legislation
Insight will monitor changes to modern slavery legislation in Australia and other jurisdictions, particularly the Republic of the Philippines, and will update the policy as legislation evolves.

References
Modern Slavery Act 2018 (Australia) https://www.legislation.gov.au/Details/C2018A00153
Register of Modern Slavery Statements (Australia) https://modernslaveryregister.gov.au/
Modern Slavery Act 2015 (UK)
https://www.legislation.gov.uk/ukpga/2015/30/contents/enacted
Modern Slavery Statement Registry (UK) https://modern-slavery-statementregistry.service.gov.uk/
International Labour Organisation – Background on modern slavery.
https://www.ilo.org/global/topics/forced-labour/lang–en/index.htm