Modern Slavery Policy

Honey Group Modern Slavery Policy

1. Purpose

Honey Group and its affiliated companies are committed to conducting business ethically and responsibly. We have zero tolerance for modern slavery, human trafficking, forced labour, child labour, servitude and other forms of exploitation within our operations and supply chains. This Policy establishes Honey Group’s commitment to preventing modern slavery, complying with the Modern Slavery Act 2018 (Cth), protecting human rights, and promoting ethical labour practices throughout our business.

2. Scope

This Policy applies to all Honey Group entities, directors, employees, contractors, labour hire personnel, consultants, suppliers, manufacturers, distributors, agents and business partners operating in Australia and internationally. It applies across all business activities including procurement, manufacturing, warehousing, logistics, sales, installation and support services.

3. Definitions

Modern Slavery: Includes slavery, servitude, forced labour, debt bondage, deceptive recruiting, child labour, human trafficking and other exploitative practices.
Supplier: Any organisation providing goods or services to Honey Group and/or its related entities.
Supply Chain: All organisations, labour and services contributing to Honey Group (and/or related entities) products or services.

4. Policy Statement

Honey Group will:

  • Maintain zero tolerance towards modern slavery.
  • Conduct business fairly, ethically and lawfully.
  • Respect internationally recognised human rights.
  • Identify and manage modern slavery risks within operations and supply chains.
  • Expect suppliers to maintain equivalent ethical standards.
  • Refuse to knowingly engage suppliers involved in exploitative labour practices.

 

5. Responsibilities

Executive Management

  • Provide leadership, resources and oversight for implementation.
  • Review the effectiveness of this Policy annually.

Procurement

  • Undertake risk-based supplier due diligence before onboarding and periodically thereafter.
  • Assess suppliers operating in higher-risk countries or industries.
  • Require suppliers to comply with Honey Group’s Terms & Conditions of Purchase.
  • Maintain supplier due diligence records.

Managers

  • Promote awareness within their teams.
  • Investigate reported concerns promptly.
  • Implement corrective actions where required.

Employees

  • Complete required training.
  • Comply with this Policy.
  • Immediately report suspected modern slavery.

 

6. Supplier Due Diligence

Honey Group will apply a risk-based due diligence process that may include supplier questionnaires, assessment of country and industry risk, contractual commitments, review of labour practices, and corrective action plans where required. Suppliers identified as presenting unacceptable risk may be suspended or removed.

7. Reporting

Any employee, contractor or supplier who suspects modern slavery must report the matter immediately to management. Reports will be treated confidentially where possible, investigated promptly and without retaliation against the person making the report in good faith.

8. Non-Compliance and Remediation

Where modern slavery risks or breaches are identified, Honey Group will investigate the matter, work with the supplier or affected party to implement corrective actions, monitor progress and, where necessary, suspend or terminate the business relationship.

9. Training and Awareness

Honey Group will provide periodic training for employees involved in procurement, supplier management, manufacturing and quality. Awareness material may also be provided to suppliers and contractors.

10. Monitoring

Honey Group will monitor the effectiveness of this Policy through supplier assessments, internal audits, training completion records, corrective action monitoring and periodic management review.

11. Review

This Policy will be reviewed at least annually, or earlier where legislation, business operations or identified risks require amendment.