Acumenis Pty Ltd ("Acumenis", "we", "us", "our") is committed to taking reasonable steps to ensure that modern slavery and human trafficking do not occur within our operations or supply chains.
We are not required to report under the Modern Slavery Act 2018 (Cth), but we have adopted this policy because we work with clients who care about how we approach these issues, and because we recognise the broader responsibility to contribute to the elimination of exploitation.
1. About this policy
This policy applies to our directors, employees, contractors, and the suppliers and partners we engage. It covers our operations and our procurement and supply chain relationships.
2. What we mean by modern slavery
Modern slavery refers to serious forms of exploitation that deprive a person of their freedom, including human trafficking, slavery and servitude, forced labour, debt bondage, deceptive recruitment, forced marriage, commercial sexual exploitation, and child labour as defined under international standards. These are criminal offences under Australian law.
3. Our operations
Acumenis is an Australian consultancy. All of our staff are employed directly in Australia under lawful employment agreements, with fair remuneration and safe working conditions. We conduct right-to-work and proof-of-age checks for new hires.
We do not use offshore labour, labour hire arrangements, or informal contracting structures.
4. Our supply chain
Our supply chain is small and primarily Australian. It consists mainly of providers of technology, software, professional services, and office services. The inherent modern slavery risk in these categories is low, but it is not zero, and we take reasonable steps to manage it.
Before engaging a new supplier, we consider the nature of the goods or services being provided, where the supplier is based, and whether the category is one in which modern slavery risks are more commonly reported. For higher-risk categories or larger commitments, we seek assurance that the supplier complies with modern slavery and labour laws, and we may include relevant obligations in our agreements.
We expect our suppliers to comply with applicable modern slavery and labour laws, to be transparent about subcontracting arrangements, and to cooperate with any enquiries we make. We reserve the right to discontinue a supplier relationship where we are not satisfied with their ethical standards.
We acknowledge that our visibility into the practices of our suppliers' own suppliers is limited. We focus our effort where we have realistic ability to influence outcomes.
5. Risk review
We review our supply chain and our operations periodically to identify changes in risk. Reviews consider the sectors and geographies our suppliers operate in, the nature and scale of the work, and publicly available risk indicators. We adjust our approach in response to legislative changes, industry guidance, and what we learn from these reviews.
6. Training and awareness
We include modern slavery awareness in our staff onboarding, and we provide more detailed guidance to people involved in procurement, vendor selection, or contract management. We update our internal guidance when risk factors change or new legislation emerges.
7. Reporting concerns
If you have concerns about modern slavery or unethical labour practices in connection with our operations or supply chain, please contact us using the details at the end of this policy. We investigate concerns promptly and fairly, maintain confidentiality, and protect anyone reporting in good faith from retaliation. Where investigation identifies a problem, we take corrective action.
8. Roles and responsibilities
The Managing Director is accountable for this policy and its implementation. Operations and delivery leads conduct supplier risk assessments and due diligence. All staff are expected to act consistently with this policy and to raise concerns where they see them.
9. Review
We review this policy at least annually, or earlier if there are significant changes to our operations, the regulatory environment, or our risk profile. We keep an internal record of versions and approval dates.
10. Contact
You can contact us about this policy or to report a concern by emailing or writing to:
Modern Slavery Officer, PO Box 17
Darling Heights, QLD, Australia 4350
Email: feedback@acumenis.com.au