Modern Slavery Policy

Gilchrist Connell wholeheartedly support the principles of internationally recognised human rights standards (United Nations Universal Declaration of Human Rights and the International Labour Organisation Declaration on Fundamental Principles and Rights at Work) and will not tolerate any exploitation, servitude, child labour, forced labour, human trafficking, debt bondage, slavery like practices, forced marriage and deceptive recruiting for labour or services.

This policy supports our commitment to continually seek to limit risks of modern slavery practices in our business and supply chain.

This policy applies to you if you are involved in our business, including if you are an employee, director, officer, labour hire staff, contractor or other representative of our business or of any business in our supply chain.

While this policy is not part of any contract you may have with us, you are expected to comply with it.

If you do not comply with this policy, we may end our business relationship with you and if you are an employee, you may be disciplined or dismissed.

Modern slavery is depriving a person of freedom for commercial gain and in violation of fundamental human rights.

It describes situations where offenders use coercion, threats or deception to exploit victims and undermine their freedom.

Modern slavery involves serious exploitation, not sub-standard working conditions or the underpayment of workers although this may be unlawful for other reasons.

Modern slavery can take many forms including:

• Slavery - owning a person, trading in slaves or financing slave trading (i.e. human trafficking);
• Forced labour - forcing a person to work by coercion or threats (and servitude is when that person’s freedom is significantly restricted);
• Forced marriage - a marriage without free and full consent – e.g. due to lack of understanding or duress/coercion;
• Debt bondage – a person works to pay off a large debt, for an unlimited time or where the value of the work is not applied to the debt;
• Deceptive recruiting – a recruiter charges a fee for the job offer, confiscates identity documents, deceives a person about personal freedom or their ability to leave the job;
• Child labour - not always unlawful but not tolerated by us when it involves exploiting children, depriving them of education, making them work in unsafe working environments.

Modern slavery can be complex and multi-faceted and can be difficult to spot.

Modern slavery indicators may include where a person:

• is not in possession of their own passport, ID or travel documents;
• is acting as though they are being instructed or coached by someone else;
• allows others to speak for them when spoken to directly;
• is dropped off and collected from work;
• is withdrawn or appears frightened or have physical indicators of slavery, such as injuries;
• unable to contact friends or family freely;
• has limited social interaction or contact with people outside their immediate environment;
• story contains obvious errors;
• acts with hostility or have difficulty in concentrating due to trauma;
• has few possessions;
• has little or no control over their finances or no access to a bank account, or they are being significantly overcharged for their accommodation; and
• is living in a very poorly maintained and overcrowded place.

These indicators are not exhaustive and do not necessarily mean there are modern slavery practices. Sometimes there may be other reasons or circumstances that indicate that something is not right.

Gilchrist Connell is committed to responsible corporate behaviour.

Limiting modern slavery practices is ethically and socially responsible, is good business practice, protects our workers and enhances our reputation.

It also supports us in assessing and addressing modern slavery risks as required by modern slavery legislation and by our clients.

Gilchrist Connell is a law firm operating in Australia. We employ predominantly professionally qualified, highly skilled people on a permanent basis. Our suppliers comprise various goods and services required to carry out the provision of legal services.

We have assessed our business as a low modern slavery risk. We will, however, remain vigilant to any risk and:

• establish processes and procedures to actively identify, address and monitor modern slavery risks in our business and supply chain;
• take steps to raise your awareness of modern slavery risks, including by having this policy;
• develop grievance and reporting mechanisms;
• operate on a continuous improvement cycle to ensure our modern slavery risks are properly addressed.

You must take all reasonable steps to ensure your/our business and supply chain is free of modern slavery practices.

However senior you are and regardless of your business relationship with us, you must pay close attention to the high-risk areas identified in the 2023 Global Slavery Index, particularly supply chain and outsourcing from High Risk Regions, High Risk Sectors and increased risks from Emerging Trends.

Some areas of the business are likely to have more exposure than others, including procurement and sourcing, human resources, finance, risk, and leadership.

Examples of specific responsibilities include:

• participating in all training, including in this policy;
• complying with our processes and procedures to identify, assess and monitor modern slavery risks in our supply chain;
• remaining alert to indicators of slavery;
• reporting any concerns to the Head of Risk and Compliance.

Turning a blind eye is unacceptable and if you reasonably suspect there may be modern slavery, report it under this policy.

If you have a reasonably held suspicion of modern slavery practices, discuss your concerns with Donna Ebert, Head of Risk and Compliance, phone 08 8215 7015 debert@gclegal.com.au, who will decide a course of action and provide any further advice.

If there is immediate danger call the police — don’t tackle a situation on your own as dangerous criminals can be behind modern slavery and human trafficking.

Not all victims may want to be helped and sometimes, reporting a suspected trafficking case puts the potential victim at risk, so it is important that unless there is immediate danger, you discuss your concerns first with the Head of Risk and Compliance before taking any further action.

Keep your eyes and ears open—your awareness and actions may stop someone from being exploited or abused.

Our Executive team are responsible for this policy and will review reports of modern slavery concerns.