Modern Slavery Policy
1. Summary
1.1. The purpose of this policy is to demonstrate Caring for You Nursing Agency’s (C4U) commitment to
identifying, preventing, and mitigating modern slavery risks in our operations and supply chains.
1.2. This policy aligns with our values and commitment to ethical practices and compliance with allapplicable laws, including the Modern Slavery Act 2018 (Cth).
2. Scope
2.1. This policy applies to all directors of the Board, management, staff, and contractors engaged and
undertaking work on behalf of C4U, wherever they may be located.
2.2. This policy covers our operations, activities, and all dealings with third parties, whether they are
private organisations, individuals, or representatives of such entities.
2.3. Compliance with this policy is the responsibility of all C4U personnel, irrespective of an individual's
role or responsibilities.
2.4. C4U expects our suppliers to uphold the same standards, including in their dealings with their
suppliers. We commit to working in partnership with our suppliers to implement and adhere to this
policy, ensuring ethical practices throughout our supply chains.
3. Modern Slavery Definition
3.1. Modern slavery refers to situations where coercion, threats, or deception are used to exploit victims
and undermine their freedom.
3.2. This includes human trafficking, slavery, servitude, forced marriage, forced labour, debt bondage,
deceptive recruiting, and the worst forms of child labour.
4. C4U's Commitment
4.1. C4U is dedicated to:
• Identifying and assessing risks of modern slavery practices in our operations and supply chains.
• Ensuring corporate governance oversight on modern slavery risks.
• Working collaboratively with suppliers to address and mitigate these risks.
• Embedding modern slavery clauses in contracts with suppliers to prohibit such practices and
ensure proactive risk management.
• Investigating any reports of modern slavery practices within our operations and supply chains
and taking appropriate remedial actions.
5. Supplier Code of Conduct
5.1. C4U has a Supplier Code of Conduct which requires all suppliers to:
• Oppose and refrain from any activities that may cause, contribute to, or encourage modern
slavery.
• Comply with all applicable laws and regulations aimed at preventing, mitigating, and reporting
modern slavery.
• Continuously assess and address modern slavery risks within their operations and supply chains.
• Report any identified modern slavery risks or practices to C4U.
• Provide necessary information to help us fulfill our commitment to this policy and legal
compliance.
6. Due Diligence Practices
6.1. C4U employs several due diligence practices to ensure compliance:
• Pre-screening potential suppliers for modern slavery risks.
• Incorporating modern slavery clauses into contracts.
• Conducting regular supplier risk assessments.
• Ensuring legal authorisation of workers to work in Australia, including necessary work permits
and visas.
• Ensuring no recruitment fees are charged to workers.
• Assessing workers sense of freedom to leave their job and experiences of threats or violence in
the workplace.
• Ensuring the workers retain control of their identification documents and has never been forced
to hand them over to an employer or recruiter.
• Promoting fair wages and safe working conditions.
• Supporting the rights to freedom of association and collective bargaining.
7. Grievance Mechanism, Response, and Remediation
7.1. C4U has established a formal process for employees and suppliers to report modern slavery
concerns. This process includes:
• Providing accessible channels for reporting grievances, such as a dedicated email address and
contact number.
• Ensuring confidentiality and protection against retaliation for those reporting concerns.
• Promptly investigating and addressing reported incidents.
• Taking corrective actions to prevent recurrence and mitigate harm to affected individuals.
8. Training and Awareness
8.1. As part of the onboarding process, C4U will:
• Require new employees to read and understand the Modern Slavery Policy.
• Provide access to additional resources to new employees to ensure they are aware of their rights
and the protections in place against modern slavery and human trafficking.
• Have new employees sign an acknowledgment statement confirming their understanding of
their rights and stating that they are not experiencing any conditions that conflict with modern
slavery protections.
8.2. To build capacity and awareness, C4U will also:
• Require training to be completed on modern slavery risks to employees in relevant roles.
• Offer general training to all current staff to enhance understanding and recognition of modern
slavery issues.
• Engage with suppliers to increase their awareness and capability to address modern slavery
risks.
9. Monitoring
9.1. C4U will regularly monitor and review the effectiveness of our actions to mitigate modern slavery
risks. This includes:
• Tracking and reporting on due diligence activities.
• Assessing the effectiveness of training programs.
• Evaluating the performance of grievance mechanisms.
• Reviewing and updating this policy to ensure it remains relevant and effective.
10. Reporting Concerns
10.1. Employees, suppliers, and other stakeholders are encouraged to report any suspected modern
slavery practices within C4U’s operations or supply chains. Reports can be made through:
• Directly contacting the Compliance Team at (03) 9771 2500
• Emailing the Compliance team at compliance@caringforyou.net.au
11. Consequences of Non-Compliance
11.1. Non-compliance with this policy by employees may result in disciplinary action, up to and including
termination of employment.
11.2. Suppliers found to be in breach of this policy may face contract termination and other legal actions.
12. Policy Review
12.1. C4U is committed to continuous improvement in our approach to modern slavery.
12.2. We will regularly assess our policies, procedures, and practices to ensure they remain effective in
identifying and mitigating modern slavery risks.
12.3. This policy will be reviewed on a biennial basis by the People & Culture Manager. Any proposed
changes this policy must be approved by the CEO.