1. Purpose
Owl Watch Services is committed to upholding the highest ethical standards and ensuring that modern slavery and human trafficking have no place within our operations or supply chains. We recognise our legal and moral responsibility to combat all forms of modern slavery in compliance with both the Modern Slavery Act 2018 (Cth) and the Modern Slavery Act 2018 (NSW).
We acknowledge that the security industry, particularly through subcontracting and labour supply chains, can be vulnerable to risks of exploitation. As such, we are dedicated to taking a proactive approach to identifying, preventing, and mitigating risks associated with modern slavery.
2. Scope
This policy applies to all employees, officers, contractors, suppliers, business partners, and any third parties acting on behalf of Owl Watch Services. It extends to all aspects of our business, including recruitment, procurement, service delivery, and supply chain management.
3. Commitment to Preventing Modern Slavery
Owl Watch Services is committed to:
- Ensuring that all workers, regardless of their role or employment status, are treated with dignity and respect.
- Implementing strict hiring and recruitment practices to prevent forced labour and exploitation.
- Conducting risk assessments to identify and mitigate modern slavery risks in our operations and supply chains.
- Engaging only with suppliers and business partners who share our commitment to ethical labour practices.
- Establishing clear procedures for identifying, reporting, and addressing modern slavery concerns.
- Providing training and awareness programs for employees and suppliers to recognise and prevent modern slavery.
- Taking decisive action against any breaches of this policy, including terminating contracts and reporting violations to authorities.
4. Definitions
Modern slavery includes various forms of severe labour exploitation, including but not limited to:
- Forced Labor: Work performed under the threat of punishment or coercion, without voluntary consent.
- Human Trafficking: The recruitment, transport, transfer, harbouring, or receipt of persons through force, fraud, or coercion for exploitation.
- Debt Bondage: When a person is forced to work to repay a debt under unfair or exploitative conditions.
- Servitude: The condition of being forced to work and unable to leave due to coercion or deception.
- Child Labor: The use of children in employment that deprives them of their childhood, education, and well-being.
- Deceptive Recruitment: Misleading individuals about the nature or conditions of their work.
5. Risk Assessment and Due Diligence
Owl Watch Services recognises that modern slavery risks exist at various levels within our business and supply chains. To mitigate these risks, we implement the following measures: 5.1 Internal Operations
- Conduct thorough background checks on employees, contractors, and subcontractors.
- Ensure fair wages and employment conditions in line with Australian labour laws.
- Maintain clear and transparent employment contracts that outline workers’ rights and conditions.
5.2 Supply Chain Management
- Require all suppliers and contractors to adhere to our ethical sourcing and labour
policies - Conduct risk assessments on suppliers, prioritising industries and regions with known
modern slavery risks. - Regularly review supplier contracts to include anti-slavery clauses and compliance requirements.
- Engage in audits and monitoring of suppliers, with corrective action plans for any identified risks.
5.3 Third-Party Labor Providers
- Only engage labour hire companies that are licensed and compliant with Australian
labour laws. - Require labour hire firms to provide evidence of ethical recruitment practices and fair
wages. - Conduct spot-checks to ensure workers are not subject to exploitation or coercion.
6. Reporting and Compliance
Owl Watch Services encourages all employees, contractors, and stakeholders to report any concerns related to modern slavery. We ensure that reporting mechanisms are accessible, confidential, and free from retaliation.
Reports can be made through:
- Internal Reporting Channels: Employees can report concerns to their managers, HR,
or compliance officers. - Whistleblower Hotline: A confidential hotline available for anonymous reporting.
- External Reporting: Concerns may also be reported to the Australian Border Force or
other relevant authorities.
All reports will be taken seriously and investigated promptly. Where necessary, we will engage with law enforcement and take appropriate remedial action.
7. Training and Awareness
We recognise that awareness is key to preventing modern slavery. Therefore, we provide regular training to:
- Employees, particularly those in recruitment, procurement, and management, to
identify and address modern slavery risks. - Security personnel to recognise potential cases of forced labour and human trafficking
in their line of work. - Suppliers and contractors to ensure they understand and comply with our modern
slavery policy.
8. Accountability and Review
- The Senior Management Team is responsible for enforcing this policy and ensuring
compliance across all operations. - We conduct annual reviews of our modern slavery risk assessment, due diligence
practices, and supplier relationships. - This policy is reviewed periodically to reflect changes in legislation, industry best
practices, and emerging risks.
9. Consequences of Non-Compliance
Owl Watch Services takes a zero-tolerance approach to modern slavery. Any employee, supplier, or contractor found to be engaging in or facilitating modern slavery will face:
- Immediate termination of employment or business relationships.
- Reporting to relevant authorities for legal action.
- Civil or criminal penalties as applicable under Australian law.
10. Ethical Sourcing, Sustainability, and Business Ethics
At Owl Watch Services, we believe that ethical business practices, sustainability, and responsible sourcing are fundamental to maintaining integrity in our operations. We are committed to ensuring that our supply chain, procurement processes, and security services align with the highest standards of corporate social responsibility, environmental sustainability, and ethical governance.
10.1 Ethical Sourcing
We recognise that the choices we make in procurement and supplier partnerships have a significant impact on human rights and fair labour practices. Therefore, we ensure that all sourcing decisions adhere to the following principles:
- Fair Labor Practices: Partnering only with suppliers who comply with Australian labour
laws, Fair Work standards, and international human rights conventions. - Supply Chain Transparency: Conducting regular audits and assessments to ensure that
all products, uniforms, and equipment are sourced from ethical and legal suppliers. - Human Rights Protections: Rejecting any form of forced labour, child labour, or
unethical employment practices within our supply chain. - Local and Fair Trade Sourcing: Prioritising local suppliers and fair-trade products
where possible, reducing the risk of exploitation and supporting ethical businesses.
10.2 Sustainability and Environmental Responsibility
Owl Watch Services is dedicated to minimising our environmental footprint by integrating
sustainability into our security operations and business practices. We focus on:
- Reducing Carbon Footprint:
- Utilising energy-efficient security systems, low-emission patrol vehicles, and eco-
friendly uniforms. - Encouraging sustainable commuting options for our staff, such as carpooling and
public transportation. - Waste Reduction & Recycling:
- Implementing digital reporting systems to eliminate paper waste.
- Ensuring proper disposal and recycling of electronic security equipment.
- Sustainable Procurement:
- Sourcing environmentally friendly products, including uniforms, office supplies, and
electronic devices. - Engaging with suppliers who uphold environmental sustainability practices.
10.3 Business Ethics & Corporate Governance
Integrity, accountability, and fairness are at the core of our corporate governance. Owl Watch
Services upholds the following ethical business principles:
- Zero Tolerance for Corruption and Bribery: Ensuring all employees and business
partners comply with Australian anti-corruption laws. - Fair Employment Practices: Offering equal opportunities, fair wages, and a safe
working environment for all employees. - Diversity & Inclusion: Promoting a workplace culture that values diversity, respects
human rights, and prevents discrimination. - Compliance with Legal and Industry Standards: Regularly reviewing and updating our
policies to remain in alignment with Australian regulations and international best practices. - Stakeholder Engagement: Engaging with clients, employees, and communities to
ensure ethical decision-making that benefits all stakeholders.
11. Ongoing Commitment & Policy Review
As part of our ongoing commitment to sustainability, ethical sourcing, and modern slavery
prevention, Owl Watch Services will:
- Annually review this policy to ensure it reflects evolving best practices, legal
requirements, and industry trends. - Enhance supplier and employee training on ethical labour practices and sustainability
measures. - Regularly assess and report on our environmental impact to ensure we continue to
improve sustainability initiatives. - Strengthen partnerships with ethical organisations to advance responsible business
practices in the security industry.
This commitment reflects our dedication to corporate responsibility, ethical business leadership, and a sustainable future for the security sector.
12. Approval and Endorsement
This policy has been approved by the senior management of Owl Watch Services and reflects our unwavering commitment to ethical business practices and human rights protection.
Hasnain Jafri
Hasnain Jafri – Director