Last Updated: 22 August 2025
1. Purpose
The purpose of this Modern Slavery Policy is to outline MediThere Pty Ltd’s commitment to preventing and addressing modern slavery and human trafficking in all its operations and supply chains. This policy reflects our dedication to upholding human rights, ethical conduct, and compliance with the Modern Slavery Act 2018 (Cth). It ensures that MediThere contributes to the global effort to eradicate all forms of modern slavery.
2. Scope
This policy applies to all individuals and entities associated with MediThere Pty Ltd, including but not limited to:
- All employees (permanent, part-time, casual).
- Directors and Officers.
- Contractors, sub-contractors, and agency staff (including labour hire personnel).
- Volunteers and students on placement.
- All suppliers, business partners, and other third parties within MediThere’s supply chains, both in Australia and internationally.
This policy applies to all MediThere operations, services, and procurement activities.
3. Policy Statement
MediThere Pty Ltd has a zero-tolerance approach to modern slavery in any form. We are committed to conducting our business ethically and with integrity, ensuring that our operations and supply chains are free from slavery, forced labour, child labour, debt bondage, human trafficking, and other exploitative practices. We recognise that modern slavery can occur in various forms and may be hidden, and we are dedicated to implementing robust systems and controls to identify, assess, and mitigate these risks. Our commitment to human rights and ethical conduct is fundamental to our mission of providing culturally safe, person-centred care.
4. Procedures
4.1 Risk Assessment and Due Diligence
MediThere will conduct regular risk assessments to identify potential modern slavery risks within its operations and supply chains, particularly focusing on high-risk sectors or geographical areas.
Due diligence processes will be applied to new and existing suppliers and partners, including assessing their modern slavery policies, practices, and controls.
This may involve supplier questionnaires, audits, and contractual clauses requiring compliance with anti-slavery principles.
4.2 Supplier and Partner Engagement
MediThere will communicate its expectations regarding modern slavery to all suppliers and business partners. * Contracts with suppliers will include clauses requiring compliance with all applicable modern slavery laws and ethical labour practices.
We will work collaboratively with suppliers to build capacity and address any identified risks.
4.3 Employee Awareness and Training
All relevant MediThere employees will receive training on modern slavery, including how to identify potential indicators and the reporting mechanisms.
This training will be incorporated into induction processes and ongoing professional development.
4.4 Reporting and Grievance Mechanisms
MediThere will maintain clear and accessible channels for reporting concerns related to modern slavery, including through our Whistleblower Policy.
All reports will be investigated promptly, thoroughly, and confidentially, with appropriate action taken based on the findings.
We will ensure that individuals who raise concerns in good faith are protected from retaliation.
4.6 Remediation
If modern slavery is identified within our operations or supply chains, MediThere will take immediate and appropriate action to address the situation, which may include:
- Working with the affected individuals to ensure their safety and well-being.
- Collaborating with relevant authorities and non-governmental organisations.
- Implementing corrective actions with the responsible parties.
- Reviewing and potentially terminating relationships with non-compliant suppliers or partners.
4.7 Monitoring and Review
This policy and MediThere’s modern slavery risk management framework will be regularly reviewed and updated to ensure its effectiveness and compliance with evolving legislation and best practices.
Performance against this policy will be monitored through relevant KPIs and internal audits.
4.8 Modern Slavery Statement (if applicable)
If MediThere meets the reporting threshold under the Modern Slavery Act 2018 (Cth) (currently consolidated revenue of $100 million or more in a financial year), we will annually prepare and publish a Modern Slavery Statement. This statement will describe our actions to assess and address modern slavery risks in our operations and supply chains.
5. Responsibilities
- Board of Directors: Accountable for overseeing MediThere’s approach to modern slavery and approving the annual Modern Slavery Statement (if applicable).
- CEO and Senior Management: Responsible for championing this policy, allocating necessary resources, and ensuring its effective implementation across the organisation and supply chains.
- Procurement/Operations Team: Responsible for conducting due diligence on suppliers, integrating modern slavery clauses into contracts, and engaging with suppliers on compliance.
- Human Resources (HR) Team: Responsible for employee training, managing internal grievance mechanisms, and ensuring ethical labour practices within MediThere’s direct employment.
- All Individuals (Employees, Contractors, etc.): Responsible for understanding this policy, identifying and reporting any suspected instances of modern slavery, and adhering to ethical conduct in all work-related activities.
6. Definitions
|
Term |
Description |
|
Modern Slavery |
As defined by the Modern Slavery Act 2018 (Cth), it refers to situations where coercion, threats, or deception are used to exploit individuals and deprive them of their freedom. This includes slavery, servitude, forced labour, forced marriage, debt bondage, deceptive recruiting for labour or services, and the worst forms of child labour. |
|
Supply Chain |
The sequence of processes involved in the production and distribution of a commodity or service, from the sourcing of raw materials to the delivery of the final product or service to the end-user. |
|
Human Trafficking |
The recruitment, transportation, transfer, harbouring, or receipt of persons by means of threat or use of force or other forms of coercion, abduction, fraud, deception, abuse of power, or vulnerability for the purpose of exploitation. |
|
Zero Tolerance |
A principle indicating that certain behaviours or practices are completely unacceptable and will result in immediate and serious consequences. |