• Section 1 - Purpose
• Section 2 - Scope
• Section 3 - Principles 
• Section 4 - Reducing Modern Slavery Risks
• Section 5 - Roles and Responsibilities
• Section 6 - Definitions

Section 1 - Purpose

(1) This Policy sets out the University’s commitment to Modern Slavery prevention, identification and reporting.

(2) The University is committed to:

1. protecting human rights;
2. opposing all forms of modern slavery by striving to create meaningful change in its business operations and Supply Chains and Networks;
3. raising awareness amongst staff and students about slavery-like practices, to respond to and reduce the risks of modern slavery; and
4. meeting its obligations under the Modern Slavery Act 2018 (Cth) and Modern Slavery Act 2018 (NSW).

(3) The University expects its staff, its controlled entities, and its affiliates to work together to assist the University to give effect to the Principles set out in this Policy.

Section 2 - Scope

(4) This Policy applies to:

1. staff;
2. affiliates;
3. students; and
4. controlled entities.

(5) This Policy should be read in conjunction with the University Code of Conduct, Purchasing and Procurement Policy, Serious Wrongdoing Reporting Policy, Complaints Management Policy, Professional Staff Misconduct Guidelines and the Enterprise Risk Management Policy.

Section 3 - Principles 

(6) For the purposes of this Policy, the term ‘Modern Slavery’ encompasses all of the practices to which the Modern Slavery Legislation refers.

(7) Modern Slavery may involve debt bondage and the use of violence and/or threats of violence (psychological or physical), isolation, deprivation of liberty and the withholding of critical identification documents such as passports.

(8) Certain groups within the University community, such as international students, women and children, are particularly at risk of modern slavery, including sexual exploitation and forced marriage. Refer to section 5 of this Policy for a more detailed definition of Modern Slavery.

(9) Modern Slavery includes, but is not limited to:

1. child labour: where children are exploited through slavery or similar practices, including for sexual exploitation, hazardous work which may harm their health and safety, or in the production or trafficking of drugs;
2. child abuse material: using children for production of child abuse materials, production, dissemination or possession of child abuse material and administrating a digital platform used to deal with child abuse material;
3. debt bondage: where a person's services are pledged as security for a debt and the debt is manifestly excessive, the person’s services are not applied to liquidate the debt, or the length and nature of the services are not limited and defined;
4. forced labour: where a person is either not free to stop working or not free to leave their place of work;
5. forced marriage: where coercion, threats or deception are used to make a person marry or where the person does not understand or is incapable of understanding the nature and effect of the marriage ceremony;
6. servitude: where the personal freedom of a person is significantly restricted and they are not free to stop working or leave their place of work;
7. slavery: where a person exercises powers of ownership over another, including the power to make a person an object of purchase and to use their labour in an unrestricted way; and
8. human trafficking: recruitment, harbouring and movement of a person for exploitation.

(10) The University must comply with the Modern Slavery Act 2018 (Cth) which requires it to report annually on the steps which it takes to identify and address the risk of modern slavery, and the Modern Slavery Act 2018 (NSW). This requires annual reporting on steps taken to ensure that goods and services procured by and for the University were not the product of modern slavery.

(11) The University is committed to ensuring that:

1. University operations and supply networks do not cause, involve, or contribute to modern slavery;
2. University contractors, suppliers, collaborators, and others with whom the University does business, respect and share the University’s commitment to minimising modern slavery risk; and
3. effective, efficient and transparent controls are implemented to verify that its business is being conducted in compliance with its obligations, to the extent it is reasonably able to, and to ensure continual process improvement.

(12) The University prohibits its employees from engaging in, permitting, or inducing any form of Modern Slavery, or impeding any investigation in relation to an alleged Modern Slavery incident.

(13) If an employee breaches this Policy, they could face disciplinary action, which may include termination of employment as well as legal action in the most severe circumstances.

(14) Employees will be provided with the access to training and instruction in relation to Modern Slavery risks (such as the Modern Slavery Awareness Training). Such training and instruction will address how to identify, report, and respond to any potential Modern Slavery incident or risk.

Section 4 - Reducing Modern Slavery Risks

(15) In giving effect to the Policy principles set out in Section 2, the University commits to reducing Modern Slavery risks that are within its direct control or area of influence through actions that include, but are not limited to:

1. setting the level of conduct expected of the University’s Suppliers, and performing appropriate due diligence, in accordance with the Purchasing and Procurement Policy, and, if applicable, investigating any reports of a breach in accordance with the relevant procedures; 
2. incorporating relevant clauses in the University's standard terms and conditions for supply and service contracts, if applicable;
3. ensuring effective, efficient and transparent controls are implemented through the University’s risks management processes so as to verify that its business is being conducted in compliance with its obligations, to the extent it is reasonably able to;
4. undertaking continual process improvement as part of its risk management framework, including based on the performance of the University reported annually in its annual Commonwealth Modern Slavery Statement;
5. providing support and information to groups at high risk, including international students;
6. establishing a Modern Slavery Advisory Committee to support the University’s response to Modern Slavery and compliance with the Modern Slavery Act 2018 (Cth).

(16) Where the University identifies potential risks of Modern Slavery, its response and reporting will be informed by and in accordance with the University’s Enterprise Risk Management Policy.

Section 5 - Roles and Responsibilities

(17) The University Council is responsible for approving the University’s annual Commonwealth Modern Slavery Statement, as required by the Modern Slavery Act 2018 (Cth) and authorising a member of University Council to sign the Statement.

(18) The University Council is responsible for approving the University’s annual reporting on steps taken to ensure that University operations and supply networks do not cause, involve, or contribute to modern slavery, as required by the NSW Modern Slavery Act 2018 (NSW).

(19) The Vice-President Operations is responsible for:

1. overseeing the steps taken by the University, consistent with this Policy, to ensure that goods and services procured by and for the University are not the product of modern slavery;
2. managing reports of modern slavery concerns and escalating them as appropriate.

(20) The Associate Director, Complaints and Investigations is responsible for:

1. implementing this Policy;
2. supporting University Risk Owners to develop controls, protocols, processes and procedures to support compliance with this Policy;
3. preparing the Risk Sponsors; and
4. submitting the University’s approved and signed Modern Slavery Statement annually, or as required by law, to the relevant authority.

(21) The University Risk Owners are responsible for:

1. identifying Modern Slavery risks through the University’s Enterprise Risk Management System, Protecht;
2. addressing and mitigating modern slavery risks through the implementation of effective controls, protocols, processes and procedures; and
3. reporting on the actions taken in their area each year to assist in the preparation of the University’s Modern Slavery Statement.

(22) The University Risk Sponsors are responsible for:

1. monitoring trends of Modern Slavery risk across their designated group of risks;
2. advocating for effective controls, protocols, processes and procedures to mitigate modern slavery risks; and
3. providing guidance and support to risk owners in managing Modern Slavery as it relates to their group of risks.

(23) The Modern Slavery Advisory Committee are responsible for:

1. driving and overseeing the creation of the University’s Modern Slavery Statement by the relevant deadline;
2. making recommendations to UOW’s Senior Executive with respect to key actions to be taken; and
3. promoting and championing the ongoing work of the University in combating modern slavery.

(24) Managers and Supervisors are responsible for ensuring that all staff within their operational area are informed of and comply with this Policy and any applicable controls, protocols, processes and procedures prescribed by the relevant University Risk Owner/s under this Policy.

(25) Individual staff are responsible for ensuring that they comply with this Policy and with any applicable controls, protocols, processes and procedures prescribed by the relevant University Risk Owner/s under this Policy.

Section 6 - Definitions