Modern Slavery Policy

1. Purpose

This policy sets out how VelpasConn Pty Ltd identifies, prevents, and responds to modern slavery in its own operations and in the supply chains it buys from. It states VelpasConn’s commitment, defines the conduct it will not tolerate, and points to the operational procedures and registers that carry the day-to-day due-diligence work.

This policy gives practical effect to:

• Modern Slavery Act 2018 (Cth): the reporting framework for entities with consolidated revenue of AUD $100M or more. VelpasConn is below this threshold and is not a mandatory reporting entity, but adopts the Act’s due-diligence approach as set out below.
• Criminal Code Act 1995 (Cth) Division 270: slavery, servitude, forced labour, deceptive recruiting for labour or services, and forced marriage offences.
• Criminal Code Act 1995 (Cth) Division 271: trafficking in persons and debt bondage offences.
• Fair Work Act 2009 (Cth): minimum wage, entitlements, and the s.357 prohibition on sham contracting, a common labour-exploitation risk in domestic construction that can signal heightened vulnerability.
• Labour Hire Licensing Act 2017 (Qld): labour-hire providers operating in Queensland must hold a licence, and businesses must only engage licensed providers.
• United Nations Guiding Principles on Business and Human Rights (2011) and the ILO core conventions on forced labour (C29, C105) and child labour (C138, C182): the international standards VelpasConn references when assessing supply-chain risk.

Why VelpasConn has this policy below the threshold. VelpasConn is not required to publish a modern slavery statement. The policy exists anyway for three reasons.

Principal contractors and government tenders increasingly ask subcontractors to evidence a modern slavery position before they will engage them. The underlying conduct is criminal under the Criminal Code regardless of a business’s size. And modern slavery risk is real in construction supply chains, particularly in imported building products and domestic labour-hire arrangements, so the risk is worth managing on its own terms rather than only when a statute compels it.

2. Scope

This policy applies to:

• All VelpasConn workers: Directors, employees, apprentices, contractors, and labour-hire personnel engaged on VelpasConn business.
• All VelpasConn operations: head-contract and subcontract works, office and yard operations, and procurement of every kind.
• All suppliers and supply chains: direct (Tier 1) suppliers VelpasConn contracts with, and the deeper supply chains behind the products and services VelpasConn buys.

Relationship to the Procurement Policy. This policy is the statement-level commitment. The operational due-diligence sits in IMS-POL-012 Procurement Policy (section 8), in IMS-PRO-814 Subcontractor Management and Procurement, and in IMS-FRM-016 Subcontractor Pre-Qualification Questionnaire (Part I).

This policy says what VelpasConn stands for; IMS-POL-012 section 8 and IMS-PRO-814 say how it is checked at the point of engagement. The two are read together and do not duplicate each other.

3. Definitions

Term	Definition
Modern slavery	The conduct defined as modern slavery in s.4 of the Modern Slavery Act 2018 (Cth): conduct that constitutes an offence under Divisions 270 and 271 of the Criminal Code Act 1995 (Cth), together with trafficking in persons, the worst forms of child labour, and similar practices. It covers eight practices: trafficking in persons, slavery, servitude, forced marriage, forced labour, debt bondage, deceptive recruiting for labour or services, and the worst forms of child labour.
Forced labour	Work or service exacted from a person under threat or coercion, which the person has not offered voluntarily and is not free to leave.
Debt bondage	A pledge of a person’s labour, or the labour of someone under their control, as security for a debt where the value of the work is not applied to clearing the debt or the length and nature of the work is not limited.
Deceptive recruiting	Recruiting a person for work using false or misleading representations about the nature of the work, the pay, or the conditions.
Worst forms of child labour	Child labour of the kind described in ILO Convention 182, including hazardous work likely to harm the health, safety, or morals of a child.
Supply chain	The products and services, including their components and raw materials, that contribute to VelpasConn’s own products and services. Extends beyond the direct supplier to the suppliers behind them.
Supplier or vendor	Any external party VelpasConn buys goods, services, or works from, including subcontractors, material suppliers, plant-hire firms, labour-hire providers, consultants, and technology providers.
High-risk category	A product, service, or geography with an elevated likelihood of modern slavery in its supply chain, assessed against recognised guidance such as the Global Slavery Index and Commonwealth modern-slavery sector guidance.
Remediation	The action taken to address harm to a person affected by modern slavery, prioritising the affected person’s safety and wishes over the protection of VelpasConn’s commercial position.

4. Policy Statement

VelpasConn does not tolerate modern slavery in any form, in its own operations or in the supply chains it buys from. Where VelpasConn finds it, or causes or contributes to it, VelpasConn acts to stop it and to remediate the harm.

Our commitments:

1. Zero tolerance. VelpasConn will not knowingly engage any worker, supplier, or subcontractor involved in modern slavery, and will act on credible evidence that one is.
2. Risk-based due diligence. Vendor checks are proportionate to risk. Higher-risk categories and engagements get more scrutiny, applied through the tiered due-diligence in IMS-POL-012 section 5 and the prequalification in IMS-PRO-814 section 5.1.
3. Fair labour at the front line. Every worker VelpasConn engages, directly or through labour hire, is paid at least their lawful minimum, holds the right to work in Australia, and works under safe and lawful conditions. Sham contracting is prohibited.
4. Licensed labour hire only. VelpasConn engages labour-hire providers that hold a current Queensland labour-hire licence and can evidence lawful treatment of their workers.
5. Expectations flow down. Material suppliers and subcontractors are expected to hold to the same standard and to extend it to their own suppliers. The expectation is written into Tier 3 and above contracts.
6. A safe way to raise concerns. Any worker or any person in VelpasConn’s supply chain can raise a modern slavery concern without fear of retaliation, through the channels in section 9.
7. Remediation over reputation. Where a person is harmed, their safety and wishes come first. VelpasConn does not silence or pressure a person who reports modern slavery.
8. We improve as we grow. VelpasConn reviews this policy and its due-diligence as the business and its obligations change, including the forward-looking triggers in section 13.

5. Our Operations and Supply Chains: Modern Slavery Risk Profile

VelpasConn is a Queensland commercial and residential construction company that operates as both head contractor and subcontractor. Its workforce is substantially direct. Its modern slavery exposure sits mainly in two places: the labour it engages through others, and the products it buys through extended supply chains.

Operations (lower direct risk). VelpasConn’s own employees are engaged under Australian awards and agreements, paid through a compliant payroll, and verified for the right to work. The direct-employment risk is low. The residual operational risk is in any labour engaged indirectly, covered below.

Supply chain (where the risk concentrates). For a Queensland builder, the categories most associated with modern slavery risk are:

Category	Why it carries risk
Labour hire and subcontracted trades	Domestic exploitation risk, including underpayment, visa-holder vulnerability, and sham contracting through layered subcontract chains. The most direct and controllable risk VelpasConn holds.
Cleaning and security services	Recognised high-risk service sectors in Australia, often delivered through outsourced and sub-tiered labour.
Imported building products	Bricks and clay products, stone, tiles, timber, steel, and reinforcing are produced in regions where forced labour has been documented. Risk sits beyond the direct supplier.
Solar PV, electronics, and electrical fittings	Polysilicon and electronics supply chains carry well-documented forced-labour exposure.
PPE and workwear	Garments, gloves, and footwear are sourced from textile and rubber supply chains with elevated risk.

VelpasConn buys most of these through Australian distributors rather than direct from overseas manufacturers, which gives it limited visibility past Tier 1. The response is proportionate: ask the questions VelpasConn can ask, prefer suppliers that can answer them, and escalate where an answer raises a flag. The detail is in section 6.

6. Due Diligence and Risk Management

VelpasConn manages modern slavery risk through the procurement controls it already operates, applied with a modern slavery lens.

1. Onboarding question. Tier 3 and Tier 4 vendors (per IMS-POL-012 section 5.1) are asked at engagement whether they, or any supplier in their chain, source labour, materials, or services from jurisdictions or industries with elevated modern slavery risk. For subcontractors the question is built into IMS-FRM-016 Part I. The response is filed with the engagement record.
2. Licensed labour hire. Before engaging a provider under a labour-hire arrangement within the Labour Hire Licensing Act 2017 (Qld), VelpasConn confirms the provider holds a current Queensland labour-hire licence and can evidence lawful pay, superannuation, and workers’ compensation for its workers. An unlicensed provider is not engaged for labour hire.
3. Right-to-work and fair-pay checks. Workers engaged directly are verified for the right to work in Australia and paid at or above the lawful minimum. Identity and visa evidence is collected only to the minimum necessary, verified through lawful channels, and handled under IMS-POL-008 Privacy Policy. Indirect labour is covered by the labour-hire checks above and the subcontractor flow-down below.
4. Heightened-risk contract terms. Where a vendor falls into a high-risk category, the contract adds an audit-rights clause, a sub-supplier disclosure obligation, and a right to terminate on a substantiated modern slavery breach. This applies from Tier 3 engagements with extended supply chains.
5. Supplier preference. Where price and quality are comparable, VelpasConn prefers suppliers that publish a modern slavery statement or can otherwise evidence supply-chain due diligence. This is applied as a tiebreaker under IMS-POL-012 section 9, not as a separate scoring exercise.
6. Red-flag response. A credible modern slavery red flag pauses the engagement, escalates to the Managing Director, and is handled under section 10 (remediation) and the corrective-action process in IMS-PRO-1002 Nonconformity and Corrective Action.

VelpasConn does not run a separate modern slavery audit programme. The controls above are integrated into normal procurement rather than bolted on, in proportion to its risk profile.

7. Supplier, Subcontractor and Labour-Hire Expectations

VelpasConn expects every material supplier, subcontractor, and labour-hire provider to:

• comply with the Modern Slavery Act 2018 (Cth) where it applies to them, and with Divisions 270 and 271 of the Criminal Code regardless of size;
• pay their workers at least the lawful minimum, meet superannuation and workers’ compensation obligations, and engage them under lawful conditions;
• not engage in sham contracting, and not pass work down chains that disguise an employment relationship to avoid those obligations;
• hold a current Queensland labour-hire licence where they supply labour;
• take reasonable steps to extend these expectations to their own suppliers; and
• tell VelpasConn promptly if they become aware of modern slavery in work connected to VelpasConn.

These expectations are written into Tier 3 and above contracts as a modern slavery clause (IMS-POL-012 section 10) and tested at prequalification through IMS-FRM-016.

A vendor that cannot meet them, or that is found to have modern slavery in its operations and will not remediate, is removed from the Approved Subcontractor Register (IMS-REG-018) and not engaged again.

8. Training and Awareness

1. Induction. New workers are made aware of this policy at induction (IMS-PRO-C08), including what modern slavery is and how to raise a concern.
2. Toolbox awareness. Workers in roles that engage labour hire or subcontractors are briefed on the practical signs of labour exploitation on site, through the toolbox-talk process (IMS-PRO-C11).
3. Procurement awareness. Workers with delegated procurement authority understand the high-risk categories in section 5 and the due-diligence steps in section 6.

Training is proportionate to role. A direct worker needs to know what to look for and who to tell. A person engaging subcontractors needs the due-diligence detail.

9. Reporting Concerns and Whistleblower Protection

Anyone who suspects modern slavery in VelpasConn’s operations or supply chains should report it. There is no requirement to be certain, and no penalty for a report made in good faith that turns out to be unfounded.

How to report:

• Directly to the Managing Director, or to any Director.
• Through the reporting channel under IMS-POL-007 Whistleblower Policy. A disclosure may attract the statutory whistleblower protections under the Corporations Act 2001 (Cth) where it meets that Act’s criteria; the no-retaliation commitment below applies in any case.
• Externally, where a person prefers, to 000 or the Queensland Police Service if anyone is in immediate danger, the Australian Federal Police (modern slavery and human trafficking), the Fair Work Ombudsman (pay and conditions), or the Australian Border Force.

No retaliation. VelpasConn does not tolerate any detriment to a person because they raised a modern slavery concern in good faith, whether they are a VelpasConn worker or a worker in the supply chain. Retaliation is itself a breach of this policy and of IMS-POL-006 Code of Conduct.

The Australian Anti-Slavery Commissioner (an independent statutory office established in 2024) is a further source of information and support for businesses and affected people, though the Commissioner does not investigate or enforce.

10. Remediation

Where VelpasConn finds that it has caused, contributed to, or is directly linked to modern slavery, it acts on a victim-centred basis:

1. Safety first. The immediate safety and wishes of the affected person take priority over VelpasConn’s commercial or reputational position.
2. Stop and assess. The relevant work or engagement is paused while the facts are established. VelpasConn does not investigate suspected criminal conduct itself or confront the people involved: it preserves records, calls 000 or the police where anyone is in immediate danger, and takes guidance from the Australian Federal Police or the Fair Work Ombudsman as appropriate.
3. Support the person. VelpasConn supports the affected person’s access to assistance, which may include specialist support services and, where the person wishes, referral to the Australian Federal Police.
4. Fix the cause. The engagement is remediated or ended, a corrective action is raised under IMS-PRO-1002 Nonconformity and Corrective Action, and the due-diligence gap that allowed it is closed.
5. Notify where required. Any client or principal contractor with a contractual or legitimate interest is notified where appropriate, balanced against the affected person’s safety and privacy.

VelpasConn does not treat ending a contract as the end of its responsibility. Cutting a supplier without remediation can leave the affected worker worse off, so the response is led by the harm, not by the commercial exit.

11. Assessing Effectiveness

VelpasConn assesses the effectiveness of this policy through:

• the proportion of Tier 3 and above vendors that have completed the modern slavery onboarding question;
• confirmation that every engaged labour-hire provider held a current Queensland licence;
• a yearly review of any red flags or concerns raised, how they were resolved, any supplier removals, and training completion; and
• the annual policy review (section 16).

These measures grow with the business under the section 13 triggers.

12. Roles and Responsibilities

Role	Responsibility
Managing Director	Owns this policy. Final decision-maker on any engagement involving a modern slavery red flag. Approves remediation actions. Decides any voluntary modern slavery statement.
Director (Executive)	Applies the policy within delegated procurement authority (IMS-REG-011). Escalates red flags to the Managing Director.
Project Manager	Applies the due-diligence and labour-hire checks on assigned projects. Verifies labour-hire licences and subcontractor prequalification before engagement.
Site Supervisor	Watches for signs of labour exploitation on site. Verifies that workers on site are who they should be and engaged through approved channels. Raises concerns promptly.
All workers	Understand what modern slavery is, watch for it, and report any concern. Never participate in or conceal it.

The Position-Name Register (IMS-REG-013) is the single source of truth for who currently holds each role.

13. Forward-Looking Triggers

This policy is written for VelpasConn’s current position, below the mandatory reporting threshold. It steps up automatically when the business or the law changes.

1. Reporting threshold. If VelpasConn’s consolidated revenue reaches AUD $100M in a reporting year and it otherwise meets the reporting-entity criteria under the Modern Slavery Act 2018 (Cth) (an Australian entity, or an entity carrying on business in Australia), it becomes a reporting entity and will prepare and publish an annual modern slavery statement against the seven mandatory criteria on the Commonwealth Modern Slavery Statements Register. Preparation begins ahead of the threshold so a full reporting year of data is available.
2. Voluntary statement. Below the threshold, VelpasConn may publish a voluntary modern slavery statement if a major client, principal contractor, or financier requests one. The Managing Director decides this case by case.
3. Law reform. The Commonwealth has signalled reforms to the Act, including a possible move toward a mandatory due-diligence requirement and a future review of the revenue threshold (the December 2024 government response retained $100M but did not rule out a later change). If a mandatory due-diligence obligation is legislated in a form that reaches VelpasConn, this policy and the IMS-POL-012 section 8 due-diligence are reviewed against it.
4. Client cascade. A formal client or principal-contractor requirement for modern slavery evidence beyond what this policy already provides is actioned as a change under IMS-REG-008 (Change Register).

14. Related Policies and Procedures

• IMS-POL-012 Procurement Policy (section 8 holds the operational modern slavery due-diligence this policy commits to; section 5 the tiered vendor checks; section 10 the modern slavery contract clause).
• IMS-POL-006 Code of Conduct (worker conduct, including the prohibition on participating in or concealing exploitation, and the no-retaliation standard).
• IMS-POL-007 Whistleblower Policy (the reporting channel and statutory protections referenced in section 9).
• IMS-PRO-814 Subcontractor Management and Procurement (the operational prequalification and engagement procedure for subcontractors).
• IMS-PRO-HR-001 Casual Employment Classification and Labour Hire Engagement (labour-hire verification and sham-contracting guard).
• IMS-PRO-1002 Nonconformity and Corrective Action (the corrective-action route for a substantiated red flag).
• IMS-PRO-705 Document Control (retention of modern slavery onboarding responses and engagement records).
• IMS-FRM-016 Subcontractor Pre-Qualification Questionnaire (Part I covers modern slavery, anti-bribery, and sustainability).
• IMS-REG-011 Delegation of Authority Register (procurement approval thresholds).
• IMS-REG-013 Position-Name Register (current incumbents of the roles in section 12).
• IMS-REG-015 Legislative and Standards Register (canonical citations for the legislation in sections 1 and 15).
• IMS-REG-018 Approved Subcontractor Register (where a vendor is removed under section 7).

15. References

Legislation:

• Modern Slavery Act 2018 (Cth).
• Criminal Code Act 1995 (Cth): Division 270 (slavery and slavery-like offences) and Division 271 (trafficking in persons and debt bondage).
• Modern Slavery Amendment (Australian Anti-Slavery Commissioner) Act 2024 (Cth).
• Fair Work Act 2009 (Cth): minimum entitlements and s.357 (sham contracting).
• Labour Hire Licensing Act 2017 (Qld).
• Corporations Act 2001 (Cth): Part 9.4AAA (whistleblower protections).

International instruments:

• United Nations Guiding Principles on Business and Human Rights (2011).
• ILO Conventions C29 and C105 (forced labour); C138 and C182 (child labour).
• United Nations Sustainable Development Goal 8.7 (eradication of forced labour, modern slavery, and child labour).

Australian Government guidance:

• Attorney-General’s Department: Commonwealth Modern Slavery Act: Guidance for Reporting Entities.
• Australian Border Force: Online Register of Modern Slavery Statements.
• Australian Anti-Slavery Commissioner: business guidance and resources.

16. Policy Review

This policy is reviewed annually, and immediately when:

• VelpasConn’s consolidated revenue approaches or crosses the Modern Slavery Act $100M threshold (section 13, trigger 1).
• A mandatory due-diligence obligation or a lower revenue threshold is legislated in a form that reaches VelpasConn (section 13, trigger 3).
• A modern slavery concern raised under section 9 reveals a gap in the policy or the due-diligence behind it.
• A major client or principal contractor sets a modern slavery requirement beyond what this policy provides (section 13, trigger 4).
• IMS-POL-012 section 8 or IMS-PRO-814 is restructured in a way that affects the operational due-diligence this policy relies on.

The policy owner is the Managing Director.

This policy is part of the VelpasConn Pty Ltd Integrated Management System.