Modern Slavery Policy

Purpose

At HP Energy Pty Ltd, we are committed to mitigating the risks of modern slavery practices within our business and supply chain. This policy serves as a foundation for our dedication to combatting modern slavery and is the cornerstone of HP Energy’s approach to modern slavery and human trafficking.

Applicability

This policy is applicable to all individuals involved with our business, including employees, directors, officers, temporary staff, contractors, and representatives in our supply chain. While not legally binding, compliance with this policy is expected. Failure to comply will lead to the termination of our business relationship, or, disciplinary action for employees. HP Energy has a zero-tolerance approach to any such non-compliance.

Definition of Modern Slavery

Modern slavery encompasses the deprivation of an individual’s freedom for commercial gain, violating fundamental human rights. It involves coercion, threats, or deception to exploit victims and compromise their freedom. Modern slavery includes various forms, such as:

(a) Slavery: Ownership of individuals, slave trading, or financing of slave trading (i.e., human trafficking). (b) Forced labour: Forcing individuals to work through coercion or threats, sometimes accompanied by servitude where their freedom is significantly restricted. (c) Forced marriage: Marriages without free and full consent, often due to duress or coercion. (d) Debt bondage: Individuals working to pay off a significant debt, often with no clear end or disproportionate value applied to the debt. (e) Deceptive recruiting: Recruiters charge fees for job offers, confiscating identity documents, or misleading individuals about their freedom and job conditions. (f) Child labour: The exploitation of children in unsafe working conditions, depriving them of education and other rights.

Modern slavery can be complex and challenging to identify.

Indicators of Modern Slavery

Indicators of modern slavery may include situations where an individual:

  • Lacks possession of their passport, ID, or travel documents.
  • Acts as though they are being coached or instructed by someone else.
  • Is dropped off and collected from work.
  • Appears withdrawn, frightened, or exhibits physical signs of slavery, such as injuries.
  • Has limited social interaction outside their immediate environment.
  • Shows hostility or difficulty concentrating due to trauma.
  • Owns few possessions.
  • Has limited control over finances, no access to a bank account, or is significantly overcharged for accommodation.
  • Resides in overcrowded and poorly maintained conditions.

These indicators are not exhaustive and may have other explanations.

Importance of Mitigating Modern Slavery Risks

Mitigating modern slavery practices aligns with our commitment to ethical business practices and reputation protection. It also enables us to comply with modern slavery legislation.

Our Responsibilities

We commit to: (a) Preparing a modern slavery statement as required by Australian law. (b) Identifying and addressing modern slavery risks in our business and supply chain. (c) Raising awareness of modern slavery risks, including through this policy.

Your Responsibilities

Regardless of your role or business relationship, you must actively address high-risk areas identified in our Modern Slavery Statement. These include supply chain and outsourcing in jurisdictions without adequate safeguards. Specific responsibilities include:

(a) Participating in all relevant training, including this policy. (b) Conducting appropriate checks on employees, recruitment agencies, and suppliers to ensure transparency. (c) Remaining vigilant for indicators of slavery (as mentioned above). (d) Using only approved contracts that include modern slavery clauses. (e) Adhering to our instructions regarding modern slavery.

Failure to report suspicions of modern slavery is unacceptable. If you suspect modern slavery, report it under this policy.

Reporting Modern Slavery Concerns

If you are reasonably suspicious of modern slavery practices, please discuss your concerns with our HR Department. They will determine the appropriate course of action and provide guidance. In cases of immediate danger, contact the authorities, as tackling such situations on your own can be hazardous.

Policy Ownership

Our board of directors is responsible for this policy. It will be reviewed as necessary and may be amended, replaced, or removed. The current version can be found on our website [https://hpenergy.com.au/modern-slavery-policy/].

Contact Us

If you have any questions about this policy, please contact us:

By email: info@hpenergy.com.au