MODERN SLAVERY POLICY FOR Our Race Community

1. Policy details

ABN: 76655287326 | Policy Owner: Our Race Community Board | Effective Date: 10th November 2026 | Next Review Date / Cycle: Annually

2. What is the purpose of this policy?

We have zero tolerance for modern slavery and human trafficking in all their forms. We are committed to complying with all applicable modern slavery and human rights laws, acting ethically and with integrity in all our business dealings and relationships, respecting human rights, preventing harm, and implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business operations or supply chains.

This policy applies to our organisation and its controlled entities (if any), governing our operations and supply chains through direct suppliers. Our reporting status under the Modern Slavery Act 2018 (Cth) is voluntary best-practice policy. Statutory reporting obligations depend on applicable law and the entity's circumstances, and nothing in this policy confirms that the organisation meets this threshold. This policy supports our commitment and underpins our annual modern slavery statement (https://www.ourrace.com.au/modern-slavery-statement).

3. Who this policy applies to?

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.

This policy is an internal policy and does not form part of any employment contract or commercial agreement. 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.

4. What is modern slavery?
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:

(a) Slavery - owning a person, trading in slaves or financing slave trading (ie, human trafficking)

(b)  Forced labour - forcing a person to work by coercion or threats (and servitude is when that person’s freedom is significantly restricted)

(c)  Forced marriage - a marriage without free and full consent - eg, due to lack of understanding or duress/coercion

(d)  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

(e)  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

(f)  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.

5. What are indicators of modern slavery practices?
Modern slavery indicators may include where a person:

(a)  is not in possession of their own passport, ID or travel documents;

(b)  is acting as though they are being instructed or coached by someone else;

(c)  allows others to speak for them when spoken to directly;

(d)  is dropped off and collected from work;

(e)  is withdrawn or appears frightened or have physical indicators of slavery, such as injuries;

(f)  unable to contact friends or family freely;

(g)  has limited social interaction or contact with people outside their immediate environment;

(h)  story contains obvious errors;

(i)  acts with hostility or have difficulty in concentrating due to trauma;

(j)  has few possessions;

(k)  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

(l)  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.

6. Why do we want to limit risks of modern slavery practices?
Limiting modern slavery practices makes good business sense, protecting our workers and our reputation.

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

7. What are our responsibilities?

We will endeavour to:

  1. (a)  prepare a modern slavery statement as required by Australian law;

  2. (b)  identify and address modern slavery risks in our business and supply chain; and

  3. (c)  take steps to raise awareness of modern slavery risks, including by requiring relevant personnel and procurement/sourcing staff to complete role-based modern slavery training on induction and at [insert frequency, eg annually], and maintaining training records.

8. What are your responsibilities?


9. Due diligence and risk assessment

We implement proportionate due diligence and risk management procedures across our operations and supply chains, including:

(a)  conducting periodic mapping and assessment of salient modern slavery risks across our operations and supply chain, having regard to sector, geographic location, workforce profile, sourcing models, and recruitment channels

(b)  screening prospective suppliers and carrying out risk-based due diligence prior to engagement and at annual renewal;

(c)  implementing mitigation, corrective action, and remediation processes where potential or actual modern slavery risks or impacts are identified;

(d)  maintaining appropriate monitoring, audit, and recordkeeping mechanisms to track the effectiveness of our actions; and

(e)  escalating material or serious risks immediately to executive leadership and the board of directors.

You must take all reasonable steps to ensure 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 our Modern Slavery Statement, particularly supply chain and outsourcing in jurisdictions without adequate safeguards. Some areas of the business are likely to have more exposure than others, including procurement and sourcing, human resources, finance, risk, sustainability, projects, legal and leadership. Examples of specific responsibilities include:

(f)  leading by example by making appropriate checks on all employees, recruitment agencies, suppliers, etc to ensure we know who is working for us;

(g)  remaining alert to indicators of slavery (see above);

(h)  using only approved contracts which include modern slavery clauses; and

(i)  obeying our instructions regarding modern slavery.

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

10. How do I report slavery concerns?

If you have a reasonably held suspicion of modern slavery practices, discuss your concerns with the CEO (admin@ourrace.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.

We are committed to providing a safe, confidential reporting environment. Anyone who raises a genuine concern in good faith under this policy will be supported and protected against any retaliation, victimisation, or detrimental treatment. Reports will be assessed and investigated promptly and fairly, with appropriate corrective action taken and, where appropriate and safe to do so, referral to relevant law enforcement authorities in accordance with applicable law. 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 CEO before taking any further action.

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

11. Who is responsible for this policy?

Our board of directors has overall governance responsibility for approving this policy, overseeing its implementation, receiving regular reports on modern slavery risks and reported incidents, and ensuring that the policy is reviewed at least annually. A designated management policy owner CEO coordinates day-to-day implementation, reporting and periodic review under Board oversight.

The policy may be amended, replaced or removed and the current version can be found here: https://www.example.com.au/modern-slavery-policy.

Created on Lawpath.com.au