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Modern Slavery Policy

Modern Slavery Policy

Policy on Modern Slavery


Statement from the Chief Executive Officer

Big Start Pty Ltd finds the crime of Modern Slavery abhorrent and our aim is to combat modern slavery both within our organisation and the supply chains that we impact. Our company has zero tolerance of modern slavery in all its forms and reaffirms its undertaking to understand the risks in our business and supply chain and manage those risks accordingly. We are committed to ensuring that people are treated with dignity and respect. We value the diversity of the people with whom we work and the contributions they make. We have a steadfast commitment to equal opportunities and an intolerance of discrimination and harassment and are dedicated to maintaining a workplace that is free from discrimination or harassment on the basis of race, sex, colour, religion, or age, to name just a few, or any unjust or unfair practices.

Big Start Pty Ltd shall perform deeper due diligence when considering taking on new suppliers, to better understand its policies and processes and the supply chains that it uses to perform services for Big Start Pty Ltd to ensure that its stance on combatting slavery and human trafficking and protecting human rights is equal to the standards set by Big Start. We expect and requires its suppliers to operate in full compliance with all applicable laws.

We will roll out additional phases of staff training on Modern Slavery to ensure our employees and workers understand the evolving risks and keep these at the front of their minds when they undergo their day to day roles, and that they understand the help and support that will be given to them if they report any suspected incident that they observe.

To date we have not been made aware of or discovered any incidences of human trafficking or slavery within our own business or our direct supply chain. However, as a business, we are committed to continually strive to ensure that any mistreatment of individuals is identified and eradicated at each touchpoint of our business and direct supply chain.

As a recipient of this policy, you are urged to read it, and expected to adhere to it. If you have any questions or comments on the policy, please contact Big Start’s Company Secretary, based in Perth, Western Australia, on 1300 244 456.



Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

Big Start Pty Ltd has a zero‐tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

Big Start Pty Ltd is also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2018. We expect the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards. Business relationships can be impacted if such issues are found and can lead to enforcement action, warning letters and, if timely remedies are not offered, to termination.


Policy application

The principles of this policy must be complied with or incorporated into policies within the division, business unit or Corporate Office (as applicable). This policy should be read in conjunction with Big Start Pty Ltd

  • Anti‐Money Laundering policy; and
  • Anti‐bribery and Corruption policy.


Supply Chain on PPE and Medical Devices

Our supply chain includes transforming synthetic materials into end‐user products such surgical masks, Respirators, gowns, face-shield and various Personal Protective Equipment and Medical Devices. As an effective response to the global COVID 19 pandemic we have structured a global and multi‐layered supply chain, with different types of business partners. As a company, we also have non‐trade based procurement, where we contract third parties for the supply of goods and services to support our general business operations.


Due Diligence Processes

We have developed a due diligence approach that targets those high‐risk locations, processes or activities that require the closest attention and where we can apply influence to mitigate or remediate issues, where they occur. If serious breaches of the Workplace Standards are identified in a new supplier, they are not authorised to supply us products until they have demonstrated comprehensive and sustainable remediation of the issues. If evidence is found of human trafficking, slavery‐like practices, or child labor at a prospective new supplier, they will be disqualified and the findings shared with relevant government agencies for their follow‐up.

For our direct supply chain in China, where our monitoring staff identify specific non‐compliance issues, including forced labor, suppliers develop corrective action plans to address them in a sustainable manner within a set period which are closely monitored by our team through follow up audits.


Risk Assessment

Zero tolerance includes prison labor, serious, life‐threatening health and safety conditions and repeated or systematic abuse. Threshold compliance issues include serious employment issues, serious health, safety or environmental issues and any combination of the two.

Compliance Monitoring (CM) – key industry risks such as child labor, excessive hours, forced labor, freedom of association, health and safety, and women’s rights are deeply embedded in our monitoring program, which seeks to uphold our supporting policies and guidelines.

Our risk assessment cuts across all tiers of our supply chain and are carried out on a continuous basis through worker interviews, engagement with government agencies on human rights topics or responding to changing regulatory frameworks. These are all material considerations in our risk assessments.

Where we have identified a potential risk through our risk assessment procedures, we will explore ways of remedying and mitigating these risks through due diligence, improved procurement practices or industry collaboration.

We ensure all our suppliers adhere to our policy prohibiting slavery. We enforce a strict code of compliance and do not tolerate slavery and human trafficking within our supply chains. If we find evidence of a failure to comply with our policy prohibiting these types of acts, we will seek to terminate our relationship with the relevant supplier.


Measurement and Performance Standards

Internal and external audits are conducted at our suppliers’ factories to ensure they comply with the relevant labor laws.


Communication and Awareness of this Policy

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, will be provided as necessary.

Our zero‐tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.


Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

Big Start Pty Ltd will seek to terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.