1.  PURPOSE

Business plays an important role in respecting and promoting human rights.  The Australian Modern Slavery Act 2018 took effect on 1 January 2019 and was established with the aim of controlling and eradicating modern slavery.

Modern slavery is a serious crime and Pragma is committed to safeguarding human rights and reducing the risk of Modern Slavery by working with all our stakeholders to fulfil this common goal.

2. WHAT IS MODERN SLAVERY

Modern slavery is depriving a person of freedom for commercial gain in violation of human rights.  The Act describes modern slavery as situations where coercion, threats or deception are used to exploit victims and undermine their freedom.  The Act defines modern slavery as including eight types of serious exploitation:

• Trafficking in persons
• Slavery
• Servitude
• Forced labour
• Forced marriage
• Debt bondage
• Child labour
• Deceptive recruiting for labour or services

Modern slavery can happen in any industry and any country.  Modern Slavery victims are often vulnerable to exploitation due to the background, migration status or structural factors like poverty.  Both adults and children can be victims of modern slavery, with women and children often especially vulnerable.

The types of exploitation can be complex, multi-faceted and difficult to spot.  Examples of risks that could arise in Pragma’s business may include:

• Underpayment or exploitation of migrants and vulnerable persons by subcontractors engaged by Pragma
• Labour conditions or child labour in the supply chain of manufactured goods sourced locally and overseas

3. WHAT ARE PRAGMA’s RESPONSIBILITIES

Pragma is working on implementing effective systems and controls to understand, manage and minimise instances of modern slavery within business operations and its supply chain.  This includes:

• Undertaking modern slavery risk assessments to identify, prevent and alleviate modern slavery risks in operations and supply chains;
• Establishing a supplier code of conduct for implementation within our operations and supply chains to ensure suppliers engage ethically in all dealings by compliance to all locate, national and other applicable laws and regulations in the countries in which they operate relating to modern slavery;
• Requiring our subcontractors to take reasonable steps to identify and address modern slavery risks;
• Raising awareness of modern slavery risks, including staff awareness through communication and training;
• Continuously reassessing and improving our processes to assist in bringing an end to modern slavery.

4. WHAT ARE PRAGMA’S EXPECTATIONS

Pragma expects that all persons involved in Pragma’s operations, which includes employees, directors, subcontractors, suppliers and any other service providers, shares its commitment to acting lawfully and ethically and will take all reasonable steps to adhere to this policy.  Compliance includes leading by example, remaining alert to indicators of modern slavery and taking action if suspected cases of modern slavery are exposed.

A breach of this policy will be taken extremely seriously and will result in an immediate investigation and action plan for remedy of the breach.

5. HOW TO REPORT MODERN SLAVERY CONCERNS

Any concerns of a suspected/potential risk of modern slavery should be raised with the Director (Angelo Alateras) and/or Office Manager (Karen Martin) on (03) 9560 5655 or info@pragmadesign.com.au as a matter of urgency.  If there is an imminent danger to the vulnerable person(s), the police should be contacted immediately.

6. MODERN SLAVERY STATEMENT

This policy is Pragma’s commitment to ensure, to the best of its ability, that there is no modern slavery in any part of the business operations.  Pragma is committed to acting ethically and with integrity in all business dealings and relationships to ensure modern slavery is not taking place within the business or its supply chain.