Policies / Modern Slavery Statement

Modern Slavery Statement for Fiscal Year 2020

This Modern Slavery Statement is made in accordance with the Australian Modern Slavery Act 2018 (Cth). It applies to describes the steps that we, Lee Brothers International Trade Pty Ltd (“TUFFWEAR”), have taken during the financial year end 30 June 2020 to ensure the absence of modern slavery occurring in the businesses or their supply chains.

Introduction

Statement from Managing Director

TUFFWEAR recognizes the importance of combating modern slavery, a crime that affects communities and individuals across the globe. We endorse a purposeful mission to improve the lives of others, as well as a passionate commitment to opportunity for all. Accordingly, we are wholly opposed to such abuses of a person’s freedoms in our direct operations, our indirect operations, and our supply chains.

We are proud of the business standards TUFFWEAR upholds, as set out in the TUFFWEAR Standards of Business Conduct (see https://www.tuffwear.com.au/Policy_Supplier_Code_of_Conduct.aspx) and are proud of the steps we have taken, and are committed to build upon, to ensure that the risks of modern slavery in our business, operations or our supply chains are addressed and removed.

Meaning of Modern Slavery

This statement is made for the purpose of satisfying the requirements of the Australian Modern Slavery Act 2018 (Modern Slavery Legislation). For the purposes of this statement, the definition of modern slavery is based on the definitions set out in the Modern Slavery Legislation. We recognize that modern slavery can occur in many forms, such as slavery, servitude, forced labor, child labor, human trafficking both in persons and children, organ trafficking, and workplace abuse and it can include the restriction of a person’s freedom of movement whether that be physical, non-physical.

Our Business and Operations

TUFFWEAR is an industry leading brand which supplies high-quality Work Wear, Corporate Wear, Safety Wear & PPE.

TUFFWEAR operates its Head Office in Sydney, other Australian based distribution centres and offices, and with interests in China. The company employs approximately 100 people across these locations.

Our Supply Chains

Given the nature of our business, the products and services (including labor) that contribute to TUFFWEAR’s own products and services are sourced from third party product suppliers and service providers and our supply chains may extend beyond direct suppliers. The following identifies where the risks of modern slavery practices may arise:

Products provided by suppliers – Finished products such as garments, footwear, and safety protective equipment.

Services provided by suppliers – Categories of service providers that are used include but are not limited to: IT services, cleaning, and transport logistics.

Products and services used by indirect suppliers – TUFFWEAR is aware that some of its indirect suppliers are based in certain sectors in which are recognized as having higher modern slavery risk such as cotton production. TUFFWEAR ensures that our suppliers are required to disclose the details of their subcontractors as we work towards full traceability of our supplier chains. We support Better Cotton Initiative (BCI) to better management of modern slavery risks.

Our Policies and Practices

TUFFWEAR is committed to ensure that there is no modern slavery exposure in our business, operations, and supply chain. It is also crucial that our suppliers represent TUFFWEAR with equal integrity towards their own customers, employees and stakeholders.

TUFFWEAR has taken due diligence processes in relation our businesses and supply chains to examine the risk of modern slavery and implement necessary safeguards to eliminate that risk.

Risks of Modern Slavery Practices

  • In TUFFWEAR Operations: There are no risks that TUFFWEAR’s operations may directly result in modern slavery practices. Our employees have fair remuneration and have been treated equally. It complies with all applicable employment legislation and industrial awards. All divisions monitor and address human rights issues in their operations under TUFFWEAR’s Code of Conduct. TUFFWEAR is also committed to improve the safety, health, and wellbeing of its employees.
    • TUFFWEAR has certain polices in place to assist in preventing modern slavery in business or operations including following:
      • TUFFWEAR_STD_Conditions of Employment
      • TUFFWEAR_STD_Equal Employment Opportunity Policy
      • TUFFWEAR_STD_Ethics and General Code of Product
      • TUFFWEAR_STD_Grievance Policy
      • TUFFWEAR_STD_Procurement Policy
  • In TUFFWEAR supply chains: TUFFWEAR has established a good management system for our supplier chains and has developed and implemented assessment safeguards against modern slavery including:

    We have taken steps to:
    • Assess where our company’s greatest risk of slavery occurs by drawing up an initial high level assessment of our supply chains, including direct and indirect suppliers, labour providers and contractors based upon geography, the product or service we are being provided with and the nature of the business transactions to identify low, medium and high risk suppliers;
    • Evaluating whether to issue questionnaires to high risk suppliers and service providers requesting information regarding due diligence procedures within their own supplier chain;
    • Incorporate this issue into our existing compliance risk assessments, and compliance monitoring activities which are carried out at the various business units at regular intervals.
    • Conducting site visits, where required

Actions to Address Risks of Modern Slavery

In keeping with our commitment to act with integrity in all our business dealings, we assess and address the risk of modern slavery occurring specifically by implementing relevant policies, due diligence, training, remediation, and other mitigating activities developed by TUFFWEAR to assist in addressing identified risks, including:

  • Contractual Terms and Conditions: Our Procurement Policy ensures that we undertake appropriate due diligence checks in the appointment of suppliers including site visits of factories, to establish their credibility, legitimacy, and ability to manage labour rights, through applicable terms and conditions in written contracts we obligate our suppliers to maintain the same standards of business conduct as ourselves.
  • Reviews of contracted suppliers: We take a risk-based approach when deciding whether to conduct detailed due diligence on a supplier, based on factors including goods or services, and supplier, to the assessment of our suppliers and engage with them to communicate our expectations.
  • Implementing action plans based on available responses, which seek to work with suppliers to resolve areas of risk to ensure the absence of modern slavery and develop channels for gathering and managing future risk information.
  • Communicating TUFFWEAR’s Ethical Sourcing and Modern Slavery Policy to suppliers. TUFFWEAR, as far as practicable, encourage its suppliers to promote best practice and continuous improvement, require its suppliers to comply with certain minimum standards and provide the TUFFWEAR with the rights of termination if the supplier is unable or unwilling to work towards full compliance with those minimum standards.
  • Resourcing for ethical sourcing and modern slavery, TUFFWEAR has a team in China, they are responsible for managing supplier relationships are central to the approach taken in all divisions in the management of ethical sourcing and modern slavery risks. Having in-country teams helps our business to understand potential ethical sourcing and modern slavery risks and build strong links with suppliers, government, and non-government organisations they source from.
  • Training and communications to ensure staff and suppliers are aware of the recent Modern Slavery legislation and provide with deeper understanding, including ways to identify ‘red flags’ of potential modern slavery risk and report such.
  • Provide access to remedy by requiring suppliers to establish grievance procedures and to establish a whistleblowing procedure.

Assessing the Effectiveness of Actions

In assessing our effectiveness in combating modern slavery, we have built upon the steps we take.

  • Reviewing the number of employees who have received the training on modern slavery; and
  • Reviewing the number of third parties which have been targeted for further due diligence processes.

Monitor and Management of Risk

The management team oversees compliances with applicable TUFFWEAR’s policies and procedures including but not limit to:

  • Review of existing monitoring and evaluation mechanisms
  • Review or establishment of appropriate grievance mechanisms and processes for remediation of harm
  • Programmatic response to reporting obligations in relevant jurisdictions

The board of directors is responsible to overseeing and approving risk management strategy and policies.

Continuous Improvements

TUFFWEAR is committed to eliminating modern slavery in all its forms, and to continuously improve policies, procedures, and systems to identify and mitigate modern slavery and ethical sourcing risks.

Approval

This policy has been approved by TUFFWEAR’s Board of Directors

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