Modern Slavery Policy

Policy

DOCUMENT DETAILS

Document Owner	Finance, Facilities, ICLT and Planning Services
Approval Date	12 February 2021
Release Date	9 March 2021
Compliance Date	9 March 2021
Review Date	1 June 2022

introduction and context

INTRODUCTION

Policy in Catholic Education Diocese of Wollongong (CEDoW) is developed to support the implementation of consistent and comprehensive practices to guide quality Catholic learning and teaching in systemic schools in the Diocese of Wollongong.

Policy is developed within the context of documents and frameworks. These include:

CONTEXT

Modern slavery includes situations where coercion, threats or deception are used to exploit people and undermine their dignity and freedom.

Modern Slavery Practices Relevant to Business violate universally recognised human rights, are crimes and they pose a serious business risk to the operations and reputation of Catholic Education Diocese of Wollongong (CEDoW). Catholic social teaching calls for the dignity of work, the rights of workers and advancing the common good.

Modern Slavery Core Principles that inform the policy enable CEDoW to prevent, and ultimately eradicate by 2030 modern slavery, by managing and mitigating risk within our operations, business relationships and supply chains.

This Policy has been developed in collaboration with the Australian Catholic Anti-slavery Network (ACAN), to support all staff in meeting Catholic Education Diocese of Wollongong's (CEDoW) compliance with legislation addressing modern slavery including Modern Slavery Act 2018 (Cth), Criminal Code Act 1995 (Cth).

EXPECTATIONS

It is expected that Staff, suppliers and business partners will take all reasonable measure to comply with this Policy.

The Catholic Education Diocese of Wollongong (CEDoW) Modern Slavery Policy must be implemented in conjunction with the following policies where relevant:

CEDoW Child Protection Policy
CEDoW Purchasing Policy

Catholic Education office RESPONSIBILITIES:

The Catholic Education Diocese of Wollongong (CEDoW) Leadership Team (or delegate(s)):

conduct a CEDoW Modern Slavery Risk Management Program that is underpinned by ethical business and in consideration of all stakeholders (including people who are at risk of and/or experience modern slavery practices)
ensure the policy and its implementation are in line with relevant Catholic Social Teaching and legal and ethical obligations
manage Modern slavery risk within CEDoW
allocate sufficient resources to provide training to staff about this policy and its application
insert appropriate anti-slavery clauses into procurement tenders and contracts
engage with suppliers and business partners to promote anti-slavery
commit to working with relevant external stakeholders to address issues, ensure effective remedy and implement prevention measures

1 RESPONSIBILITIES OF SCHOOLS

SCHOOLS MUST:

1.1	advise staff that:
	1.1.1	identification, prevention, management and mitigation of modern slavery risk is a core responsibility of all workers
	1.1.2	business operations or relationships that knowingly support, facilitate or encourage worker exploitation or Modern slavery are strictly forbidden
	1.1.3	any actual or suspected activity of non-compliance must be reported according to the *CEDoW Modern Slavery Non-Compliance Procedure*
1.2	insert appropriate anti-slavery clauses into procurement tenders and contracts
1.3	undertake supplier reviews, including self-assessments, to assess levels of modern slavery risk, commitment and capacity to manage identified risks including new companies seeking to do business

2 RESPONSIBILITIES OF STAFF

STAFF MUST:

2.1	confidentially report, any actual or potential Modern slavery risks immediately, including violations, illegal or unethical conduct according to the *CEDoW Modern Slavery Non-Compliance Procedure*
2.2	immediately escalate to the Principal, or in the case of Catholic Education Office staff, their relevant Head of Service, information they receive from outside CEDoW, of any suspected or actual modern slavery practices, indicators or red flags with CEDoW or supply chains

3 RESPONSIBILITIES OF suppliers and business partners

suppliers and business partners MUST:

3.1	support CEDoW efforts to assess the levels of risk within their operations and supply chains, and to gauge their commitment and capability to manage Modern slavery risks
3.2	demonstrate how they identify, prevent, manage and mitigate modern slavery risk to the operations and supply chains
3.3	report, any actual or potential modern slavery practices, indicators or red flags immediately to the CEDoW Modern Slavery Liaison Officer (MSLO) for investigation by the CEDoW Modern Slavery Compliance Team (MSCT)

Procedure

CEDoW Modern Slavery Non-Compliance Procedure

Implementation