Modern Slavery

Modern Slavery Policy

Currently, New Zealand does not have legislation covering Modern Slavery although a Bill is currently proceeding through Parliament. In the meantime, Tactical’s policy recognises that Modern Slavery is a crime and a violation of human rights and is defined under the Australian Modern Slavery Act 2018 (the Act) as including eight types of serious exploitation:

  • trafficking in persons.
  • slavery.
  • servitude.
  • forced marriage.
  • forced labour.
  • debt bondage.
  • deceptive recruiting for labour or services; and
  • the worst forms of child labour which means situations where children are subjected to slavery or similar practices or engaged in hazardous work.

The Purpose of this Policy is to:

  • prevent, detect, and respond with mitigating controls to the risk of Modern Slavery occurring within Tactical Solutions, its supply chain or in any other business relationships.
  • demonstrate Tactical Solution’s commitment to only doing business with those who fully comply with the Act; and
  • ensure compliance with the Act (as may be amended from time to time).

Scope

This policy applies to all persons working for and with the Tactical Solutions or on its behalf in any capacity, including employees, directors, officers, volunteers, interns, external consultants, third-party representatives, and business partners. Employees are defined as Individuals employed by Tactical Solutions, including continuing or ongoing, fixed term, casual and seasonal employees, and contractors.

Policy Statement

Tactical Solutions has a zero-tolerance approach to Modern Slavery.

Tactical Solutions is committed to acting ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure Modern Slavery is not taking place anywhere in its own business operations or supply chains. Tactical Solutions is also committed to ensuring there is transparency in its approach to tackling Modern Slavery throughout its business and supply chains, consistent with the Tactical Solutions disclosure obligations under the Act.

The prevention, detection and reporting of Modern Slavery in any part of Tactical Solutions business and supply chains is the responsibility of all those working for it or under its control. Employees who also include contractors, are encouraged to raise concerns with their manager or a Company Director, about any likely Modern Slavery breaches in any parts of Tactical Solution’s supply chains or business, at the earliest possible stage. Tactical Solutions expects the same high standards from all its contractors, suppliers and other business partners. Tactical Solutions contracting processes will include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and expect suppliers to hold their own suppliers to the same high standards.

Policy Program

Tactical Solutions Modern Slavery program contains the following elements:

1. Policies

Tactical Solutions currently has employment agreements that include a whistle-blowing policy in its standard employment agreements. These policies support awareness of acceptable practice and behaviour; and the reporting mechanisms exist to raise concerns of inappropriate behaviour.

Work is currently underway to create and implement further policies that cover Fraud, Bribery, Foreign Bribery and Corruption.

2. Procedures

Tactical Solutions will meet the requirements under Modern Slavery Acts, both in Australia where the legislation already exists, and in New Zealand, when it is enacted, in three ways:

1)    Procurement of goods and services (Procurement Policy and Procedure)

The procurement framework is the key mechanism whereby suppliers are engaged by Tactical Solutions. The procurement framework provides for due diligence on these suppliers and their compliance with the Act. Procuring goods and services will, as far as reasonable, be conducted in a way as to ensure that Tactical Solutions sources goods and services from entities that comply with their obligations under the Act. The extent of the due diligence conducted in the procurement process will depend on the types of goods or services being sourced. Some examples of the due diligence that may be conducted include requesting:

  • self-assessment/attestation that the supplier complies with various provisions in the Act.
  • a copy of the supplier’s most recent Modern Slavery statement (if applicable).
  • details of structure and operations of their supply chain; and/or
  • details of the actions taken by the supplier to manage and address modern slavery risks in their supply chain. If a proposed contract is included as part of the procurement, consideration must be given to a provision ensuring compliance with the Act.

2)    Contract management and monitoring key suppliers/offshore partners.

The adoption of anti-slavery wording in contracts to cover compliance with the Act. The obligations in the clause to include:

  • Obligation to comply with the Act.
  • A requirement to take reasonable steps to ensure that there is no modern slavery in the contractor’s supply chains or any subcontractor’s supply chains; and
  • A requirement to notify Tactical Solutions if the supplier becomes aware of any actual or suspected breach of the Act.

Tactical Solutions will work collaboratively with key suppliers/business partners to identify and manage modern slavery risks and develop commercial and actionable solutions.

3)    Statement Preparation, Endorsement and Approval

The NZ Act will require that an annual statement be prepared and approved for each financial year where the Company has a revenue of at least $100 million. If required, the annual statement will be approved by the company’s directors and signed by one the company’s directors. At this point, Tactical Solutions is not required to participate (due to its size) but will act within the spirit of the proposed law at all times.

Responsibilities

Procurement Team:    The Procurement Team are responsible for overseeing sourcing activity, ensuring that an assessment of suppliers is conducted (where appropriate) on their compliance with the Modern Slavery Act.

Human Resources:     Staff responsible for Human Resources are responsible for addressing modern slavery risks in the recruitment process particularly when dealing with consultants and agencies in the recruitment of personnel, contract workers, consultants, casual workers and others.

Managing Directors:   The Managing Directors are responsible for overseeing offshore partnerships and ensuring that an assessment of offshore partners is conducted on their compliance with the Modern Slavery Act. They are also responsible for ensuring the Procurement and Human Resources staff are meeting their responsibilities under company policies.

The Managing Directors are responsible for preparing the annual Modern Slavery Statement, if required, supported by the Procurement Team.

The Managing Directors are the policy owner.

Records Management

The policy owner will maintain a record of issues relevant to the Modern Slavery Policy for consideration at the time of review.

Legislation and Standards

Australian Act: https://www.legislation.gov.au/Details/C2018A00153

New Zealand Bill:  https://www.parliament.nz/media/9121/modern-slavery-reporting-bill.pdf

 

Contact Information

If users have any questions or suggestions regarding our privacy policy, please contact us (Tactical Solutions Ltd) through our Contact Us page.