Modern Slavery Policy

The Tank Stream – A St Giles Hotel is committed to operating with the highest integrity and in an ethical manner. This commitment includes respect for human rights and a zero-tolerance approach to Modern Slavery and human trafficking.  The Tank Stream will not knowingly support or deal with any business involved in slavery, human trafficking and child or sexual exploitation.

What is Modern Slavery?

Modern Slavery is a serious violation of an individual’s dignity and human rights.  Exploitation practices including human trafficking, slavery servitude, forced labours, debt bondage and forced marriage are all considered Modern Slavery and are serious crimes under Australia Law.

The Modern Slavery Act 2018 (NSW) recognises Modern Slavery is prevalent around the world and in New South Wales, and sets out steps to ensure New South Wales is not contributing to these crimes.

The Act seeks to tackle Modern Slavery occurring in New South Wales and in the supply chains of New South Wales organisations – whether that conducts occurs within the state, the country or internationally.

Objectives

The purpose of this Policy is to detail our responsibilities and that of our suppliers and partners in observing and upholding The Tank Stream’s position of zero-tolerance to modern slavery and human trafficking. This Policy applies to all areas of our business.

Responsibilities

  • The Board of Directors and the Management has overall responsibility for ensuring this policies complies with our legal and ethical obligations.  This includes, but is not limited to, preventing the use of our hotel for the sexual exploitation of adults and children, recruitment of employees or agency workers via unauthorised agencies or subcontractors exposing the company to the potential risk of indirectly supporting unethical employment practices such as forced or bonded labour.
  • The success of this policy and the delivery of our responsibilities will be supported by the Board of Directors, the General Manager and all the levels of employees of the hotel.
  • Employees at all levels, Directors, Officer, Agency Workers, Volunteer, Intern, Contractors, External Consultants, Third Parties representatives and business partners are required to support and promote our commitment to anti-slavery and human trafficking prevention measures.
  • Upon identification of an incident or suspicion of activity, which could be construed as modern slavery and human trafficking, we will work with all interested parties to ensure that the appropriate action is taken and preventative measures adopted to reduce the likelihood of a reoccurrence.
  • Ethical Recruitment Policy
    • The Human Resources Teams and all Managers who are delegated the responsibility for the recruitment of workers, must understand their responsibilities and carry out “right to work” checks, to ensure they met the legal compliance.  This requires full identification checks to take place including passports and, where relevant work permits/visa.  This process will be carried out and audited whenever there is any new intake of workers from the agents.
    • As part of the company’s due diligence, all potential providers of agency are required to complete and sign a declaration confirming that they are fully compliant with the requirements of Australia Immigration legislation and the Modern Slavery Act.
    • As part of the process, the Management will hold face-to-face meetings with agencies, 3rd party contractors and recruitment agencies. The purpose of these meetings was to reinforce our Management’s zero tolerance approach to Modern Slavery and human trafficking.
  • Whistle Blowing Policy – At all times, Tank Stream Hotel will conducts its business with the highest standards of integrity and honesty. We also expects all employees to maintain the same standards in everything they do.  All level of employees are therefore encouraged to report any wrong doing by the Company or its colleagues that falls short of these business principles.  To support this, a totally confidential and independent whistle blowing call service continues to be available to all level of employees.
  • Whilst primarily directed at our employees, the policy also supports and encourages all stakeholders, including suppliers and business partners, to disclose any concerns they may have without fear of recrimination.
  • Management of suppliers – All potential suppliers will be required to confirm their compliance with the Modern Slavery Act.  In addition, the potential suppliers must agree to the Company’s right to verify and confirm all relevant documents such as passport, work permit / visa to ensure that the supplier met all legal requirements.
  • Management at all levels are responsible to ensure that those reporting to them understand and comply with this policy. Adequate and regular training must be carried out with our supply chains or third party contractors.
  • Management team and all level of employees of the hotel must ensure that all our supply chains/third party contractors read, understood and acknowledged that they did comply with this policy.
  • The prevention, detection and reporting of Modern Slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. They are required to avoid any activity that might lead to or suggest a breach of this policy.
  • Staff must notify your respective Manager or General Manager as soon as possible if you believe or suspect that a conflict of this policy has occurred, or may occur in the future.
  • We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
  • The company is committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our business or in any of our supply chains.
  • Detrimental treatment includes dismissal, disciplinary action, treats or other unfavourable treatment connected with raising a concern. If you believe you have suffered such treatment, you should inform the General Manager immediately.   If the matter is not remedied, and you are an employee, you should raise it formally using the Grievance Procedures which can be found in the staff handbook or from Human Resources Department.

Communication and Awareness of this Policy

  1. The Management will constantly provide training and create the awareness of this policy to all levels of employees to avoid any risk our business faces from the Modern Slavery in its supply chains.
  2. Our zero tolerance approach to Modern Slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

 Breach of this policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.  The company will terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Review

This policy and our procedures are reviewed and approved by Management as and when necessary.

Updated: 25 June 2020