HEQS Modern Day Slavery Policy

This Policy outlines HEQS requirements and expectations of its suppliers in regard to Modern Slavery. The Policy also sets out the actions undertaken by HEQS to reduce the risk of Modern Slavery in its supply chain.

Modern Slavery is a crime and a violation of fundamental human rights. It takes various forms including slavery, servitude, forced and compulsive labour and human trafficking.

HEQS has a zero tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of its business dealings and relationships.

Definitions

Modern Slavery as defined in the Modern Slavery Act 2018 (Cth) (the Act) means conduct which would constitute:

• (a) an offence under Division 270 or 271 of the Criminal Code; or
• (b) an offence under either of those Divisions if the conduct took place in Australia; or
• (c) trafficking in persons, as defined in Article 3 of the Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children, supplementing the United Nations Convention against Transnational Organized Crime, done at New York on 15 November 2000 ([2005] ATS 27); or
• (d) the worst forms of child labour, as defined in Article 3 of the ILO Convention (No. 182) concerning the Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labour, done at Geneva on 17 June 1999 ([2007] ATS 38).

Supplier means any individual, company or entity that sells or provides a product or service to HEQS.

Policy

HEQS is committed to reducing the risk of Modern Slavery within HEQS and its supply chain in accordance with its obligations under the Modern Slavery Act (Cth) 2018. HEQS requires all suppliers to comply with the Act.

Suppliers are required to investigate and report to HEQS on the modern slavery and labour practices of its supply chains to ensure compliance with the Act.

HEQS is committed to implementing and maintaining effective systems and controls to ensure compliance.

• These include:
• 1. Conducting risk assessments of its supply chain to determine areas with the highest risk of Modern Slavery
• 2. Engaging directly with selected key suppliers to assess the risk of modern slavery within the supplier and its supply chain
• 3. Ensuring contractual agreements includes compliance with the Act. Raeco reserves the right to terminate any supplier contract if there is deemed to be a breach of this Policy, HEQS Supplier Code of Conduct or the Act.

If Modern Slavery has been identified within a supplier, this supply relationship will be terminated with immediate effect.

Continuous improvement is a major focus within HEQS and this policy may be amended as a result over time.

If you believe or suspect a breach of or conflict with this policy has occurred or may occur, please notify HEQS.