VentraIP Modern Slavery Policy

This policy aims to set out how Nexigen Digital will deal with Modern Slavery within its supply chain and encourage individuals to look for and report suspected Modern Slavery.

Modern Slavery is a crime and violation of human rights and is defined under the Australian Modern Slavery Act 2018 (the Act) includes eight types of serious exploitation:

• trafficking in persons;
• slavery;
• servitude;
• forced marriage;
• forced labour;
• debt bondage;
• deceptive recruiting for labour or services; and
• the worst forms of child labour, which means situations where children are subjected to slavery or similar practices or engaged in hazardous work.

People who agree to work for the company agree to abide by and honour the spirit of this Code.

Application of the policy

This policy applies to all persons working for and with Nexigen Digital Pty Ltd trading as VentraIP or on its behalf in any capacity, including employees, directors, external consultants, third-party representatives and business partners.

Guiding principles

Nexigen Digital is committed to making sure that it does not engage suppliers that breach Modern Slavery legislation by regularly reviewing supply agreements.

Nexigen Digital is committed to holding its suppliers accountable for their commitment to eradicating Modern Slavery. It will not knowingly engage suppliers that do not align with its position on enforcing basic human rights.

Nexigen Digital will conduct risk assessments to determine which areas of its supply chain are most at risk of Modern Slavery offences and implement risk minimisation strategies.

Procuring goods and services will be conducted in a way that ensures that Nexigen Digital sources goods and services from entities that comply with their obligations under the Act. The extent of the due diligence in the procurement process will depend on the types of goods or services being sourced. 

Some examples of the due diligence that may be conducted include requesting:

• self-assessment/attestation that the supplier complies with various provisions in the Act;
• a copy of the supplier’s most recent Modern Slavery statement (if applicable);
• details of structure and operations of their supply chain; and/or
• details of the actions taken by the supplier to manage and address modern slavery risks in their supply chain. If a proposed contract is included as part of the procurement, consideration must be given to a provision ensuring compliance with the Act.

Reporting

If a team member or related person to Nexigen Digital is aware of either Nexigen Digital, a supplier or a service provided that is breaching the Modern Slavery Laws, the individual should report the breach to their direct manager. If this is not possible, the breach should be reported to a member of the executive team.

Breaches of this Policy

The breach of this policy by a team member or director of the company may lead to disciplinary action being taken in accordance with the company’s disciplinary procedure. Serious breaches may be regarded as gross misconduct.

If a supplier is identified as having an issue, we will work with them to prepare a corrective action plan and resolve all violations within an agreed-upon time period. We reserve the right to terminate our relationship with individuals and organisations in our supply chain if they breach this policy.