Workfast believes in earning our clients' trust by acting responsibly and ensuring the right decisions and actions are made for our people, our clients, our communities, and we expect the same from our suppliers. Workfast is committed to upholding human rights and combating modern slavery, not only with respect to its own employees but also for workers throughout our supply chain. We recognize that modern slavery encompasses slavery, servitude, forced labour, child labour, human trafficking, debt bondage, deceptive recruitment, forced marriage, and the worst forms of child labour.
Our Ethical Sourcing Policy encompasses comprehensive criteria on anti-corruption, labour rights, fair and safe working conditions, environmental compliance, and modern slavery prevention. This Policy establishes our commitment to conducting robust human rights due diligence across our operations and supply chains.
This Policy applies to:
- all Workfast suppliers, contractors, subcontractors, and business partners globally;
- all entities owned or controlled by Workfast;
- all procurement activities regardless of value or location; and
- the entire supply chain, from raw material sourcing to final service delivery.
This Policy is complemented by a comprehensive compliance audit program and regular risk assessments. Suppliers must implement systems to achieve compliance with both this Policy and applicable national and international laws, with the higher standard taking precedence.
This Policy aims to:
- eliminate modern slavery and human trafficking from our operations and supply chains;
- improve working conditions for workers throughout our supply chain;
- protect our corporate reputation and maintain stakeholder trust through ethical practices;
- ensure regulatory compliance with applicable laws, including the Modern Slavery Act 2018 (Cth) and its ongoing reforms;
- drive continuous improvement in responsible sourcing practices; and
- support victims of modern slavery and human trafficking.
Ethical Sourcing Criteria
- Modern Slavery Prevention
Prohibition of Modern Slavery:
- Suppliers must not engage in or facilitate any form of modern slavery, including slavery, servitude, forced labour, child labour, human trafficking, debt bondage, deceptive recruitment, forced marriage, and the worst forms of child labour.
- All workers must be employed on a voluntary basis with freedom to terminate their employment with reasonable notice.
- No worker fees, deposits, or identity document retention are permitted.
Due Diligence Requirements:
- Suppliers must conduct their own modern slavery risk assessments.
- High-risk suppliers must provide detailed supply chain mapping.
- Suppliers must implement appropriate controls based on identified risks.
- Regular monitoring and reporting of modern slavery risks is required.
Worker Rights Protection:
- All workers must understand their rights and working conditions.
- Clear grievance mechanisms must be available and accessible.
- Protection against retaliation for reporting concerns is provided.
- Support for victims of modern slavery is provided.
- Bribery and Corruption
Suppliers shall not engage in any acts of bribery, corruption, facilitation payments, or unethical business practices. This includes:
- offering, paying, soliciting, or accepting bribes;
- engaging in any form of corruption;
- making facilitation payments to expedite routine processes; and
- providing inappropriate gifts or hospitality to influence business decisions.
- Labour Rights and Freedom of Association
Freedom of Employment:
- Employment is freely chosen with no use of forced, bonded, or involuntary prison labour.
- Workers are free to leave their employer after reasonable notice.
- No retention of identity documents or requiring deposits from workers.
- Workers are free to leave the workplace after their shift.
Freedom of Association:
- Workers have the right to join or form trade unions and collectively bargain
- No interference with legitimate trade union activities
- Worker representatives have access to workplaces to perform their functions
- Where legal restrictions exist, alternative means for worker representation must be facilitated
- No discrimination against workers for union membership or activities
- Working Conditions, Health and Safety
Safe Working Environment:
- Safe and hygienic working conditions considering industry knowledge and specific hazards
- Adequate fire safety measures and structural integrity of buildings and equipment
- Regular, recorded health and safety training for all workers
- Senior management responsibility assigned for health and safety
Essential Facilities:
- Access to clean toilet facilities and safe drinking water
- Sanitary facilities for food preparation and storage where relevant
- Clean, safe accommodation meeting basic needs where provided
- Personal protective equipment available with proper training
Occupational Health:
- Health surveillance programs where required by law or risk assessment
- Regular workplace inspections and hazard identification
- Emergency response procedures and first aid facilities
- Safeguards on machinery meeting or exceeding local requirements
- Child Labour Prohibition
Strict Prohibition:
- Use of child labour is strictly prohibited
- No employment of persons under 15 years (or 14 in developing countries per ILO Convention 138)
- Young workers (15-18 years) protected from hazardous work and night work
- Any child labour discovered must be addressed with the child's best interests as priority
Protective Measures:
- Verification of worker ages through reliable documentation
- Special protections for young workers regarding working hours and conditions
- Educational support where required
- Remediation programs that prioritize child welfare
- Living Wages and Working Hours
Fair Remuneration:
- Wages meet or exceed national minimum wage or industry standards, whichever is higher.
- Wages are sufficient to meet basic needs with discretionary income.
- Written, understandable information about employment conditions and wages is provided.
- No unauthorised wage deductions or disciplinary financial penalties.
Reasonable Working Hours:
- Compliance with national laws and industry standards for working hours
- Maximum 48 hours per week excluding voluntary overtime
- At least one day off per seven-day period
- Overtime voluntary, fairly compensated, and not excessive
- Respect for break periods and holiday entitlements
- Non-Discrimination and Equal Treatment
Prohibited Discrimination:
- No discrimination based on race, caste, social background, disease, ethnic origin, religion, age, disability, gender, pregnancy, marital status, sexual orientation, union membership, or political affiliation
- Employment decisions based on ability and qualifications
- Equal access to training, promotion, and benefits
- Treatment of all workers with respect and dignity
Inclusive Workplace:
- Promotion of diversity and inclusion
- Accommodation of workers with disabilities
- Protection of vulnerable groups
- Cultural sensitivity and respect
- Regular Employment and Fair Contracts
Employment Relationships:
- Work is performed through recognised employment relationships.
- No avoidance of labour or social security obligations through contracting arrangements.
- Legitimate apprenticeship programs with real skills development.
- Minimised use of fixed-term contracts unless justified.
Fair Contract Terms:
- Clear, written employment contracts in workers' preferred language
- Transparent terms and conditions
- Protection of workers' legal entitlements
- Fair termination procedures
- Prohibition of Harsh Treatment
Workplace Conduct:
- No physical abuse, discipline, or threats of physical abuse.
- No sexual or other harassment.
- No verbal abuse or intimidation.
- Respectful treatment of all workers.
- Clear disciplinary procedures that are fair and documented.
- Entitlement to Work and Immigration Compliance
Legal Employment:
- Only workers with a legal right to work shall be employed.
- Verification of work authorisation through original documentation.
- Compliance with immigration laws and regulations.
- Fair treatment of migrant workers.
- No exploitation of vulnerable immigration status.
Agency Worker Protections:
- Due diligence on labour agencies and recruiters
- No charging of recruitment fees to workers
- Fair treatment equivalent to direct employees
- Clear contracts and working arrangements
- Subcontracting and Home Working
Prior Approval Required:
- No subcontracting without Workfast's prior written consent
- Due diligence on all subcontractors and home workers
- Extension of policy requirements throughout subcontractor networks
- Regular monitoring of subcontractor compliance
- Safe working conditions for home workers
- Environmental Compliance and Sustainability
Environmental Standards:
- Compliance with all applicable environmental laws and regulations.
- Proper disposal of production waste.
- Identification and management of key environmental impacts.
- Controls to minimise environmental footprint.
- Sustainable resource management practices.
Climate Responsibility:
- Commitment to reducing greenhouse gas emissions.
- Energy efficiency measures.
- Sustainable material sourcing.
- Circular economy principles where applicable.
- Implementation and Compliance
Due Diligence Framework - Risk Assessment
- Annual risk assessments of all suppliers based on geography, sector, and business model.
- Enhanced due diligence for high-risk suppliers and regions.
- Regular review and updating of risk profiles.
- Integration with procurement decision-making processes.
Supplier Screening
- Pre-qualification requirements including ethical sourcing questionnaires
- Background checks and verification of credentials
- Review of previous compliance history
- Assessment of management systems and controls
Ongoing Monitoring
- Regular compliance audits (announced and unannounced)
- Supplier self-assessments and reporting
- Stakeholder feedback and grievance mechanisms
- Continuous improvement planning
- Audit and Verification
Audit Program
- Risk-based audit schedule with annual reviews for high-risk suppliers
- Independent third-party audits where appropriate
- Worker interviews and document review
- Corrective action planning and follow-up
- Verification of remediation efforts
Documentation Requirements
- Maintenance of comprehensive supplier records
- Evidence of policy communication and training
- Incident reporting and response documentation
- Regular compliance reporting to senior management
- Training and Capacity Building
Internal Training
- Regular modern slavery awareness training for procurement staff.
- Specialised training for audit teams and compliance officers.
- Senior management briefings on emerging risks, including legislative reform developments.
- Integration with general ethics and compliance training.
Supplier Development
- Capacity building programs for suppliers.
- Technical assistance for compliance improvement.
- Sharing of best practices and resources.
- Collaborative industry initiatives.
- Grievance Mechanisms and Remediation
Accessible Reporting
- Multiple channels for reporting concerns (hotline, email, online portal).
- Anonymous and confidential reporting options.
- Clear procedures for investigation and response.
- Protection against retaliation for good faith reporting.
Remediation Process
- Immediate action to address any identified modern slavery.
- Victim-centred remediation approach.
- Cooperation with law enforcement where appropriate.
- Long-term corrective measures to prevent recurrence.
- Regular monitoring of remediation effectiveness.
- Transparency and Reporting
Public Reporting
- Annual Modern Slavery Statement as required by applicable laws.
- Public disclosure of key performance indicators.
- Stakeholder engagement and consultation.
- Integration with sustainability reporting.
- Workfast has regard to guidance issued by the Australian Anti-Slavery Commissioner, an independent statutory office established under the Modern Slavery Act 2018 (Cth) from November 2024 to support business compliance, drive best practice, and engage with victims and survivors.
Performance Monitoring
- Key performance indicators for ethical sourcing.
- Regular supplier scorecards and ratings.
- Trend analysis and benchmarking.
- Continuous improvement targets.
- Governance and Accountability
Role
Responsibilities
Managing Director
Overall accountability for policy implementation; resource allocation and strategic oversight; board and stakeholder reporting; policy approval and review.
Compliance Manager
Day-to-day policy implementation and monitoring; supplier relationship management; audit coordination and follow-up; training program delivery; incident investigation and response.
Procurement Team
Integration of ethical sourcing criteria in procurement decisions; supplier screening and evaluation; contract management and monitoring; issue identification and escalation.
- Contract Requirements
Mandatory Contractual Terms
- Comprehensive ethical sourcing clauses in all supplier contracts
- Right to audit and inspect facilities
- Termination rights for serious breaches
- Indemnification and liability provisions
- Requirement for suppliers to flow down requirements to subcontractors
- Non-Compliance and Enforcement
Progressive Enforcement
- Initial Non-Compliance: Warning and improvement plan with timeline
- Continued Non-Compliance: Formal notice and enhanced monitoring
- Serious Breaches: Suspension of business relationship
- Egregious Violations: Immediate termination of contracts
Factors in Enforcement Decisions
- Severity and scope of non-compliance
- Willingness to cooperate and remediate
- Previous compliance history
- Impact on affected workers
- Availability of alternative suppliers
- Continuous Improvement
Regular Review and Updates - Policy Review
- Annual comprehensive policy review.
- Updates to reflect regulatory changes.
- Integration of lessons learned and best practices.
- Stakeholder feedback incorporation.
- Benchmarking against industry standards.
- Ongoing monitoring of reforms to the Modern Slavery Act 2018 (Cth), including the Federal Government’s July 2026 proposal for a new offence of failing to prevent modern slavery for large reporting entities, mandatory due diligence obligations, and civil penalties for non-compliance; this Policy and associated due diligence processes will be updated as reforms are enacted.
System Enhancement
- Regular assessment of due diligence processes
- Technology upgrades for monitoring and reporting
- Training program effectiveness evaluation
- Supplier feedback integration
- Performance metric refinement
- Reporting and Disclosure
Internal Reporting
- Quarterly compliance reports to senior management
- Annual board reporting on policy effectiveness
- Integration with risk management reporting
- Performance dashboard maintenance
External Disclosure
- Annual Modern Slavery Statement publication
- Sustainability report integration
- Stakeholder consultation summaries
- Public performance data disclosure
APPENDIX 1
International Standards Compliance
Fundamental ILO Conventions:
- C87: Freedom of Association and Protection of the Right to Organise Convention, 1948
- C98: Right to Organise and Collective Bargaining Convention, 1949
- C29: Forced Labour Convention, 1930
- C105: Abolition of Forced Labour Convention, 1957
- C138: Minimum Age Convention, 1973
- C182: Worst Forms of Child Labour Convention, 1999
- C100: Equal Remuneration Convention, 1951
- C111: Discrimination (Employment and Occupation) Convention, 1958
Additional Standards:
- UN Guiding Principles on Business and Human Rights
- ILO Declaration on Fundamental Principles and Rights at Work
- Universal Declaration of Human Rights
- OECD Guidelines for Multinational Enterprises
Regulatory Compliance:
- Modern Slavery Act 2018 (Cth), including the Modern Slavery Amendment (Anti-Slavery Commissioner) Act 2024 (Cth), which established the Australian Anti-Slavery Commissioner from 7 November 2024
- Applicable state and federal workplace legislation
- International modern slavery and human trafficking laws
- Environmental protection regulations
- Anti-corruption and bribery legislation
