Modern Slavery Policy for Brand Impact (Creative Identity Pty Ltd)
ABN: 56 163 916 925
Brand Impact (Creative Identity Pty Ltd) is committed to ensuring that modern slavery has no place in our supply chain. This guide outlines how to identify risks, report unethical practices, and measure the effectiveness of our efforts to prevent modern slavery.
Modern Day Slavery refers to situations where individuals are exploited and cannot refuse or leave due to threats, violence, coercion, deception, or abuse of power. It is an umbrella term that includes various forms of severe exploitation, such as:
- Forced Labour: People are forced to work against their will under threat of punishment.
- Human Trafficking: The recruitment, transportation, or harboring of people through force, deception, or coercion for exploitation purposes.
- Debt Bondage: The most widespread form of slavery, where people are forced to work to repay a debt, often with unfair or unclear terms, effectively trapping them in labor.
- Child Labour: The exploitation of children for work, depriving them of education, health, and a childhood, often involving dangerous or exploitative conditions.
- Forced Marriage: Individuals, particularly women and girls, are forced into marriage without their consent and cannot leave.
- Domestic Servitude: Victims are forced to work in households under abusive conditions, often isolated from outside help or protection.
- Slavery-Like Practices: This can include practices like forced sexual exploitation, servitude, or any situation where someone is treated as property.
How to Spot Modern Slavery Risks
Modern slavery can exist in many forms, including forced labor, child labor, and human trafficking. It is crucial to identify the signs and risks of modern slavery within our supply chain to ensure compliance with ethical standards. This section outlines key indicators to help our staff and suppliers recognize potential issues.
- Multiple employees being paid into the same bank account, suggesting control over their wages.
- Workers who appear fearful, anxious, or under surveillance, which could indicate coercion or threats.
- Employees working longer hours than legally permitted or without appropriate breaks.
- Workers living in substandard conditions provided by the employer, especially if they are not free to leave.
- Physical signs of abuse or neglect, such as injuries, malnutrition, or exhaustion.
- Individuals who have limited freedom of movement or are not allowed to leave their place of work.
Grievance Mechanism for Reporting Unethical Practices
If you have reason to believe that unethical practices, including modern slavery, are occurring within Brand Impact’s supply chain, you can report your concerns through one of the following channels:
- Contact our CEO, Peter Morkos, at peter@creativeidentity.com.au or call 0433 658 176.
- If you prefer to remain anonymous, you may send an anonymous letter outlining your concerns to our head office.
- Report concerns to the relevant statutory or legal authorities in Australia:
- Australian Border Force (ABF): slavery.reporting@abf.gov.au | +61 1300 555 135
- Fair Work Ombudsman +61 13 13 94 | https://www.fairwork.gov.au/
- Australian Human Rights Commission +61 1300 656 419 |https://humanrights.gov.au
- Safe Work Australia +61 1300 551 832 | https://www.safeworkaustralia.gov.au/
- Crimestoppers +61 1800 333 000 | https://www.crimestoppers.com.au/
International Organisations for Reporting Unethical Practices:
- International Labour Organization (ILO):
- Website: ILO Forced Labour
- Email: ilo@ilo.org
- Phone: +41 22 799 6111 (Geneva, Switzerland headquarters)
- United Nations Office on Drugs and Crime (UNODC):
- Website: UNODC Human Trafficking
- Email: unodc-hq@un.org
- Phone: +43 1 26060 (Vienna, Austria headquarters)
- Walk Free – Global Modern Slavery Organisation:
- Website: Walk Free
- Email: info@walkfree.org
- International Organization for Migration (IOM):
- Website: IOM Counter-Trafficking
- Email: hq@iom.int
- Phone: +41 22 717 9111 (Geneva, Switzerland headquarters)
Measuring Effectiveness in Preventing Modern Slavery
Brand Impact is committed to continuously improving its processes to prevent modern slavery. We have implemented a framework to measure the effectiveness of these efforts, focusing on custody and control of the supply chain.
- We collect data from the point of sourcing raw materials, particularly high-risk materials like cotton, through to the final product delivery.
- All suppliers are required to provide detailed documentation about their operations, including independent audits and certifications such as SA8000.
Independent Audits
Regular independent audits are conducted at least once every two years. These audits verify that suppliers comply with our ethical standards and include reviews of working conditions and wage compliance.
Key Performance Indicators (KPIs)
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- Percentage of suppliers who have undergone independent audits and complied with all required standards.
- Number of grievances or reports of unethical practices received and resolved.
- Number of corrective actions implemented as a result of audit findings.
Continuous Improvement
Brand Impact is dedicated to regularly reviewing its procedures, conducting follow-up audits, and working with suppliers to ensure compliance with modern slavery prevention.
Next Review: Annual or as needed
Reviewed by Peter Morkos & Executive Team