Modern Slavery Policy
1. Introduction
Modern slavery is a term that encompasses various forms of exploitation and abuse of human rights, such as forced labour, human trafficking, debt bondage, child labour, and servitude. Modern slavery can occur in any industry and any country and affects millions of people around the world.
Pro AV Solutions is a technology integration firm that provides audio visual solutions for various sectors, such as education, health, corporate, defence and government. Pro AV Solutions does not manufacture any hardware but procures equipment from a variety of manufacturers and suppliers, both locally and internationally.
Pro AV Solutions is committed to conducting its business in a responsible and ethical manner, and to respecting the human rights of all people involved in its operations, supply chain, and communities. Pro AV Solutions has a zero-tolerance policy towards any form of modern slavery, and expects the same from its business partners, contractors, and suppliers.
2. Purpose and Scope
The purpose of this policy is to outline Pro AV Solutions’ approach to identifying, preventing, and addressing the risk of modern slavery in its business and supply chain, and to comply with the Modern Slavery Act 2018, which requires certain entities to report on their actions to assess and address modern slavery risks.
This policy applies to all employees, directors, officers, and contractors of Pro AV Solutions, and to any third parties that have a business relationship with Pro AV Solutions, such as suppliers, agents, distributors, and consultants.
3. Responsibilities
Pro AV Solutions’ Board of Directors is responsible for approving and reviewing this policy, and for overseeing the implementation of Pro AV Solutions’ modern slavery strategy and reporting.
Pro AV Solutions’ Management Team is responsible for ensuring that this policy is communicated and adhered to by all staff and contractors, and for developing and monitoring the effectiveness of Pro AV Solutions’ modern slavery due diligence processes and procedures.
Pro AV Solutions’ Procurement Team is responsible for engaging with suppliers and manufacturers, and for conducting risk assessments and audits of Pro AV Solutions’ supply chain, in accordance with Pro AV Solutions’ Supplier Code of Conduct and Supplier Audit Program.
All employees, contractors, and business partners of Pro AV Solutions are responsible for complying with this policy, and for reporting any suspected or actual incidents of modern slavery to Pro AV Solutions’ Management Team or through Pro AV Solutions’ Whistleblower Policy.
4. Risk Assessment and Due Diligence
Pro AV Solutions recognises that its business and supply chain may be exposed to the risk of modern slavery, especially in countries or sectors where labour standards and human rights are not adequately protected or enforced. Pro AV Solutions is committed to conducting regular and thorough risk assessments and due diligence of its operations and supply chain, to identify, assess, and mitigate any potential or actual modern slavery risks.
Pro AV Solutions’ risk assessment and due diligence process includes the following steps:
- Mapping and reviewing Pro AV Solutions’ business activities and supply chain, and identifying the countries, sectors, and suppliers that pose a higher risk of modern slavery.
- Engaging with suppliers and manufacturers and requesting them to provide information and evidence of their compliance with Pro AV Solutions’ Supplier Code of Conduct, which sets out Pro AV Solutions’ expectations and requirements regarding labour and human rights, environmental and social responsibility, and ethical business practices.
- Conducting audits and site visits of selected suppliers and manufacturers, either by Pro AV Solutions’ Procurement Team, GPA partners or by independent third parties, to verify their compliance with Pro AV Solutions’ Supplier Code of Conduct and to identify any gaps or issues that need to be addressed.
- Taking appropriate actions to remediate any non-compliance or adverse impacts identified in the audits, such as requiring suppliers and manufacturers to implement corrective action plans, providing training and capacity building, or terminating the business relationship in case of serious or repeated violations.
- Monitoring and reviewing the performance and progress of suppliers and manufacturers and providing feedback and support to improve their compliance and performance.
- Reporting and disclosing Pro AV Solutions’ modern slavery risks, actions, and outcomes, both internally and externally, in accordance with the Modern Slavery Act 2018 and Pro AV Solutions’ Transparency and Accountability Policy.
5. Training and Awareness
Pro AV Solutions is committed to raising awareness and understanding of modern slavery among its employees, contractors, and business partners, and to providing them with the necessary training and guidance to comply with this policy and to prevent and report any incidents of modern slavery.
Pro AV Solutions’ training and awareness program includes the following activities:
- Providing all new and existing employees and contractors with a copy of this policy and Pro AV Solutions’ Supplier Code of Conduct and requiring them to acknowledge their acceptance and compliance.
- Delivering regular and tailored training sessions to employees and contractors, especially those who are involved in procurement, sales, and project management, on the definition, indicators, and impacts of modern slavery, and on Pro AV Solutions’ modern slavery strategy and reporting.
- Communicating and engaging with suppliers and manufacturers and providing them with information and resources on modern slavery and Pro AV Solutions’ Supplier Code of Conduct and requiring them to participate in training and capacity building programs.
- Promoting and participating in industry and multi-stakeholder initiatives and forums on modern slavery and sharing best practices and learnings with peers and stakeholders.
6. Reporting and Remediation
Pro AV Solutions encourages and expects all employees, contractors, and business partners to report any suspected or actual incidents of modern slavery in Pro AV Solutions’ business or supply chain, either to Pro AV Solutions’ Management Team or through Pro AV Solutions’ Whistleblower Policy, which provides a confidential and anonymous reporting mechanism and protects the rights and interests of whistleblowers.
Pro AV Solutions will investigate and respond to any reports of modern slavery promptly and thoroughly and will take appropriate actions to remediate any adverse impacts and prevent their recurrence, in consultation and collaboration with the affected parties and stakeholders.
Pro AV Solutions will also report and disclose any incidents of modern slavery and the actions taken to address them, both internally and externally, in accordance with the Modern Slavery Act 2018 and Pro AV Solutions’ Transparency and Accountability Policy.
7. Review and Improvement
Pro AV Solutions will review and update this policy and its related processes and procedures on an annual basis, or as required by changes in legislation, regulation, or business circumstances. Pro AV Solutions will also monitor and evaluate the effectiveness and impact of its modern slavery strategy and reporting and will seek to continuously improve its performance and practices.
8. Access to this Policy
This policy will be made available to all Company team members and officers by the following means:
- The policy will be uploaded to the Company intranet.
- On implementation, the policy will be communicated to all team members and officers by way of email.
- The policy will otherwise be disclosed to team members on commencement of employment.
- To ensure persons outside the Company can access the policy, the policy will also be published on the Company’s website.
9. Breaches of this Policy
All team members and contractors of the Company are required to comply with this policy at all times.
Non-compliance with this policy may result in disciplinary action up to and including termination of employment or termination of a contractor’s services.
10. Variations
This policy may be varied, amended, replaced or terminated from time to time and at any time at the absolute discretion of the Company.
