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Modern Slavery Policy - Mk3 Group

Introduction

Mk3 Group upholds the values of Unity, Excellence, Responsiveness and Ambition and to being a trusted claims management company for 25 years. Since the start of our operation, we are committed to having policies and procedures that ensure adherence to all employment laws and human rights. Modern slavery is a criminal offence, and the Mk3 Group has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships, as well as implementing and enforcing effective systems and controls to ensure modern slavery does not exist anywhere in our own business or in any of our supply chains.

Purpose

Modern Slavery as defined under the Australian Modern Slavery Act 2018 (the Act) includes eight (8) types of serious exploitation:

  1. Trafficking in persons;

  2. Slavery;

  3. Servitude;

  4. Forced marriage;

  5. Forced labour;

  6. Debt bondage;

  7. Deceptive recruiting for labour or services; and

  8. The worst forms of child labour which means situations where children are subjected to slavery or similar practices or engaged in hazardous work.

The purpose of this policy is to:

  1. Prevent, detect, and respond with mitigating controls to the risk of Modern Slavery occurring within the Mk3 Group, its supply chain or in any other business relationship.

  2. Demonstrate the Mk3 Groups commitment to only doing business with those who fully comply with the Act; and

  3. Ensure compliance with the Act (as may be amended from time to time).

Policy Statement

We are committed to providing a work environment free from any violation of human rights that exploits a person(s) for personal or commercial gain such as slavery, servitude, forced labour and human trafficking.

We are also committed to ensuring transparency in our own operations and in our approach to combating modern slavery throughout our supply chains, in accordance with our disclosure obligations under the Act.

Who this Policy Applies to

This policy applies to all individuals who work for the Mk3 Group or on our behalf in any capacity, including employees, directors, contractors, external consultants, third-party representatives, and business partners. Every employee in the Mk3 Group has a role to play in ensuring that our operations and our supply chain are free from modern slavery practices.

Our Suppliers

Mk3 Group compliance to the Act and this policy extends to our contractors, suppliers, and other business partners. We will continue to include specific prohibitions against the use of forced, compulsory, or trafficked labour, as well as anyone held in slavery or servitude, whether adults or children, in our contracting processes, and we expect our suppliers to hold their own suppliers to the same standards and expectations.

Policy Responsibilities

Mk3 Group will implement and maintain robust policies and procedures to prevent modern slavery. This includes but is not limited to policies on recruitment, employment, and ethical business practices. We have a robust Recruitment policy that not only ensures compliance within our hiring process but set clear expectations and reinforce that our recruitment supply chain is free from modern slavery.

Mk3 Group is responsible for the implementation of this policy, monitoring its usage and effectiveness, dealing with any questions, and reviewing internal control systems and processes to ensure they are successful in combating modern slavery.

 

Mk3 Group’s management team will ensure that all employees understand and comply with the policy. The companies expectation is that all employees undertake the relevant training supplied internally through our online training platform. This training is to be completed annually to ensure all employees have awareness of modern slavery, participate in meeting our compliance obligations and assist in eliminating modern slavery.

Any feedback, suggestions or queries are encouraged and should be addressed to the Group General Manager or the Risk and Compliance Manager.

Policy Compliance

Employees, Suppliers, Contractors, and other Business partners must read, understand, and enforce this policy. The prevention, identification, and reporting of modern slavery in any element of our company or supply chains is the duty of everyone who works for the Mk3 Group or is under the companies authority. Employees must refrain from engaging in any action that might lead to or imply a violation of this policy.

If there is reason to believe that a conflict with this policy has occurred, is happening, or may occur in the future, please contact the Group General Manager or the Risk and Compliance Manager as soon as possible. Employees are urged to express concerns about any issue or suspicion of modern slavery in any aspect of our business or any supplier tier’s supply chain as soon as possible.

Alternatively, all employees have access to the Mk3 Group Whistleblower policy that allows employees to report any concerns related to modern slavery without fear of reprisal. Reports will be thoroughly investigated, and appropriate action will be taken.

If you have any doubts about whether a specific act, the treatment of employees in general, or their working circumstances inside any tier of our supply chains represents any of the numerous types of modern slavery, please contact the Group General Manager or the Risk and Compliance Manager.

 

Dismissal, disciplinary action, threats, or other unfavourable treatment as a result of voicing a concern is considered detrimental treatment. If you suspect you have been subjected to such treatment, you should immediately notify the Group General Manager immediately.

Communication and Awareness

Mk3 Group focuses on ensuring our management team, at all levels, is not only responsible for abiding by this policy, but also know how to address any relevant concerns raised by an employee(s).

Training will form part of the induction process for all new employees, and updates will be offered through established channels of communication between Mk3 Group and its employees.

Mk3 Group’s Whistleblower Policy protects whistleblowers by encouraging openness and support for anyone who raises a genuine concern in good faith. We are committed to ensuring no one suffers from detrimental treatment as a result of reporting their suspicions related to modern slavery.

Mk3 Group Policies

Mk3 Group's Director and Senior Management promote the values of the business and strong corporate governance so that our decisions and actions are based on the transparency, integrity, responsibility, and performance, which promotes the long-term sustainability and ongoing success of our business.

Mk3 Group has policies in key areas which include:

  • Anti-Discrimination and Equal Employment Opportunity Policy

  • Code of Conduct

  • Conflict of Interest Policy

  • Domestic and Family Violence Policy

  • Privacy Policy

  • Supplier Code of Conduct

  • Whistleblower Policy

  • Work Health and Safety Policy

  • Fair operating and trading Policy

Mk3 Group’s policies are published and available to all employees via our Intranet and Human Resources platforms. Training of these policies is a requirement when joining Mk3 Group and are repeated on a periodic basis by all employees to maintain their Risk and Compliance obligations.

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