Introduction
Outsource Compliance BPO makes this Modern Slavery Statement for the financial year ending [Date]. It is made pursuant to the Modern Slavery Act 2018 (Cth) and outlines the steps we have taken to identify, manage and mitigate the risk of modern slavery in our operations and supply chains.Outsource Compliance BPO is committed to operating ethically and with integrity in all business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place in our own business or in our supply chains.
About Our Organization
Outsource Compliance BPO is a specialized provider of outsourced Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) compliance solutions for Australian businesses subject to Tranche 2 reforms. We operate a global service delivery model with headquarters in [Location] and offshore delivery centers in [Locations].Our core services include AML/CTF program development, customer due diligence, transaction monitoring, and compliance documentation management for legal firms, accounting practices, real estate agencies, and other newly regulated sectors in Australia.
Organizational Structure
Outsource Compliance BPO operates under the following structure:
- Board of Directors providing strategic oversight
- Executive Management Team responsible for day-to-day operations
- Operational teams structured by service function
- Support functions including HR, IT, Finance, and Compliance
Our global workforce includes approximately [Number] employees across our operational locations, with delivery centers designed to provide efficient, cost-effective compliance solutions for our Australian clients.
Our Supply Chains
As a professional services provider, our supply chains primarily consist of:
- Technology Providers: Software, hardware, and cloud service providers that support our service delivery platform
- Professional Services: Consulting, legal, accounting, and other professional advisory services
- Office and Facilities: Office space, equipment, and facilities management services
- Human Resources: Recruitment, training, and employee welfare services
- Administrative Services: Basic office supplies and business support services
We recognize that certain categories within our supply chain may present higher modern slavery risks, particularly those involving offshore operations, technology manufacturing, or labor-intensive services.
Risk Assessment and Due Diligence
We have conducted a risk assessment of our operations and supply chains to identify areas where there may be a risk of modern slavery. Our assessment considered factors such as:
- Geographic Risk: Locations of operations and suppliers, particularly in regions with higher prevalence of modern slavery
- Sector Risk: Industry sectors known to have higher modern slavery risks
- Product/Service Risk: Types of goods or services that may involve vulnerable workers or high-risk processes
- Business Model Risk: How our business practices might contribute to modern slavery risks
Based on this assessment, we have identified the following areas as presenting potential modern slavery risks:
- Technology hardware procurement (particularly electronic components)
- Offshore service delivery centers in developing economies
- Facilities maintenance services (cleaning, security)
- Construction and fit-out services for our office locations
Policies and Governance
To address modern slavery risks, we have implemented the following policies and governance frameworks:
Policies
- Supplier Code of Conduct: Sets out our expectations of suppliers regarding human rights, including prohibition of forced labor and modern slavery
- Procurement Policy: Includes human rights considerations in supplier selection and management
- Whistleblowing Policy: Enables reporting of suspected modern slavery or other ethical concerns
- Human Rights Policy: Outlines our commitment to respecting human rights throughout our operations and supply chains
Governance
- Ethics Committee: Oversees implementation of our policies and addresses any reported concerns
- Supplier Due Diligence Process: Includes human rights and modern slavery risk assessment
- Regular Board Reporting: Modern slavery risks and mitigation activities are reported to the Board quarterly
- Annual Review: Comprehensive review of modern slavery risks and effectiveness of controls
Risk Management and Remediation
We take a risk-based approach to managing modern slavery risks in our operations and supply chains:
Supply Chain Management
- Pre-qualification Questionnaires: Include specific questions about labor practices and modern slavery policies
- Contractual Provisions: Require suppliers to comply with modern slavery laws and our Supplier Code of Conduct
- Supplier Audits: For higher-risk suppliers, we conduct periodic audits of labor practices and conditions
- Corrective Action Plans: Where issues are identified, we work with suppliers to implement improvements
Internal Operations
- Employee Training: All staff receive training on recognizing and reporting modern slavery concerns
- Enhanced Oversight: Additional monitoring of operations in higher-risk locations
- Ethical Recruitment Practices: Stringent procedures to ensure all employees are freely employed
- Living Wage Commitment: Ensuring all employees receive fair compensation
Remediation
If we identify modern slavery in our operations or supply chains, we will:
- Immediately investigate the circumstances
- Provide support and remedy to affected individuals
- Take corrective action against the responsible parties
- Review and strengthen our systems to prevent recurrence
- Report to relevant authorities as required
Training and Awareness
We provide modern slavery training to all employees, with enhanced training for those in roles that may expose them to modern slavery risks, such as:
- Procurement and vendor management teams
- Human resources personnel
- Operations managers, particularly in offshore locations
- Executive leadership and board members
Training includes information on:
- Recognizing indicators of modern slavery
- Our policies and procedures for addressing risks
- Reporting mechanisms for raising concerns
- The importance of ethical business practices
Assessing Effectiveness
We assess the effectiveness of our modern slavery risk management through:
- Key Performance Indicators: Including supplier compliance rates, training completion, and concerns raised
- Internal Audits: Regular reviews of our modern slavery controls
- Stakeholder Feedback: Gathering input from employees, suppliers, and other stakeholders
- External Benchmarking: Comparing our approach to industry best practices
- Incident Analysis: Reviewing any reported incidents to identify system improvements
Future Commitments
Over the next reporting period, we commit to:
- Enhancing our supplier due diligence process with more detailed modern slavery risk assessments
- Expanding training programs to increase awareness across all levels of the organization
- Collaborating with industry peers to address shared modern slavery risks
- Implementing a more comprehensive supplier audit program for high-risk categories
- Developing more robust KPIs to measure the effectiveness of our approach
Consultation Process
In preparing this statement, we consulted with all entities we own or control, including our offshore delivery centers. This consultation involved:
- Workshops with management teams from each entity
- Information gathering from procurement, HR, and operations functions
- Review and input from local compliance specialists
- Board-level oversight and approval
Approval
This Modern Slavery Statement was approved by the Board of Directors of Outsource Compliance BPO on [Date].[Signature][Name] Chief Executive Officer Outsource Compliance BPO