Modern Slavery Policy
MBK Security Group Australia (“MBK”)
1. Policy Statement
MBK has zero tolerance for modern slavery in any form, including forced labour, human trafficking, debt bondage, and child labour. We are committed to ethical business practices, human rights due diligence, and transparency across our operations and supply chains. This policy aligns with the Australian Modern Slavery Act 2018 and international standards (e.g., UN Guiding Principles on Business and Human Rights).
2. Definitions
- Modern Slavery: Exploitative practices depriving individuals of freedom for commercial gain (e.g., forced labour, human trafficking, servitude).
- Supply Chain: All entities providing goods/services to MBK (e.g., security equipment manufacturers, uniform suppliers, subcontractors, recruitment agencies).
- High-Risk Sectors: Electronics manufacturing, textiles, cleaning services, labour hire, and offshore production.
3. Scope
This policy applies to all MBK employees, contractors, suppliers, and business partners globally.
4. Due Diligence & Risk Assessment
- Risk Mapping: Annual assessments of suppliers in high-risk sectors/countries (e.g., uniform factories in Asia, electronics from conflict-affected areas).
- Supplier Vetting:
- Mandatory modern slavery declarations for new suppliers.
- Enhanced due diligence for high-risk suppliers (e.g., audits, site visits).
- Worker Voice: Anonymous grievance channels for employees and supply chain workers (via email/phone hotline).
5. Responsibilities
- Leadership: Oversee policy implementation, allocate resources, and review annual statements.
- Procurement Team: Assess supplier risks, include anti-slavery clauses in contracts, and terminate non-compliant partners.
- All Employees: Complete training, report concerns via the designated channel, and escalate red flags (e.g., withheld passports, excessive overtime).
6. Red Flags & Reporting
Employees must report indicators such as:
- Workers paying recruitment fees/debts to employers.
- Restriction of movement or communication.
- Inconsistent documentation (e.g., passports held by employers).
Reporting Channel: Email: ethics@mbksecuritygroup.com.au | Hotline: 1300 023 333
7. Training & Awareness
- Annual training for procurement, HR, and operations teams.
- Supplier workshops on ethical sourcing expectations.
- Resources accessible via MBK’s intranet.
8. Contractual Controls
All supplier contracts include:
- Compliance with modern slavery laws.
- Right to audit and inspect facilities.
- Termination for breach of this policy.
9. Remediation
If modern slavery is identified, MBK will:
- Prioritise victim safety and support (e.g., access to legal aid, counselling).
- Report to authorities (e.g., Australian Federal Police, Border Watch).
- Review systems to prevent recurrence.
10. Monitoring & Reporting
- Annual Modern Slavery Statement: Published on MBK’s website, detailing:
- Risk assessment findings.
- Actions taken to address risks.
- Training completion rates.
- Supplier audit outcomes.
- KPIs:
- 100% high-risk suppliers screened annually.
- 90% employee training completion.
11. Policy Governance
- Sponsored by: Rita Louise
- Reviewed: Annually or after significant incidents.
- Next Review Date: 30 June 2026
Endorsement
Endorsed By: Simon Downes, Chief Executive Officer
MBK Security Group Australia
Contact for Concerns
Hudda Yousuf, Ethics & Compliance Officer
Email: admin@mbksecuritygroup.com.au | Phone: 02 6541 1121