MACVAD Modern Slavery Policy

Any use of slave or trafficked labour is absolutely abhorrent to MACVAD.  We acknowledge our responsibility under the Australian Modern Slavery Act 2018 and the UK Modern Slavery Act 2015. We will take proactive steps to ensure that there is no modern slavery in our business, or those of our service providers and product suppliers


Modern slavery: Is a broad term to denote human trafficking, forced labour and slavery-like practices such as debt bondage, and the sale or exploitation of children. These crimes have a common feature – they involve one person depriving another person of their liberty in order to exploit them for personal or commercial gain.

Debt bondage: Debt bondage is a worker pledging their labour or the labour of others under the control of an employer as security for a debt; when either the real value of the work undertaken is never applied to repayment of the debt, or the length and nature of the work that must be undertaken is never fully defined or limited. The labour is not necessarily forced by violence or threats; instead, it is enforced by the worker’s forced acceptance of the obligation to repay the alleged debt.

Forced labour: Defined as all work or service that is exacted from any person under the menace of penalty and for which the said person has not offered himself voluntarily. 

Human trafficking: Defined as the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation.


The purpose of this policy is to provide clarity to all MACVAD Staff, contracted labour or service providers and suppliers of goods to MACVAD on the Company’s standards, processes, and actions that it commits to take to protect workers from the threat of modern slavery


The MACVAD Board have responsibility for implementing this policy and its objectives and will provide adequate resources and investment to ensure that modern slavery is not taking place within the business or within its supply chains.

All colleagues recruiting workers either directly or via agency providers are responsible for the application of this policy and accompanying procedures line managers and staff. All staff responsible for the purchase of goods or services are responsible for ensuring that the supplier and service providers commits to adhere to these principles

MACVAD Policy Commitment

MACVAD Commits to:

Risk Assessment: Conduct risk assessments to identify which parts of our business and which service providers and suppliers are most at risk of modern slavery so that efforts can be focused on those areas

Education: Educate by providing information on identifying and eliminating modern slavery to staff, service providers, and suppliers through training and printed workplace material

Employment: Ensure that recruitment is performed by trained staff who are trusted and aware of modern slavery and the signs to look for.

Recruitment: Ensure that where external recruitment agents or organisations are utilised, all fees are to be paid by the business. Workers are not to be charged a work finding fee.

Agency workers: Ensure that agency workers are not used. The business should have direct control over the condition under which workers are engaged.

Enable voices: Provide a platform so that suspected cases of Modern Slavery can be confidential and anonymous reported by staff or workers in the supply chain.

Investigate: Ensure that all reports of suspected modern slavery are dealt with properly and with sensitivity, and where appropriate are reported to the relevant authorities 

Act: Terminate the contract with any supplier found to have knowingly been involved in

modern slavery. Any staff involvement will be treated as ‘gross misconduct’.

Refine. Follow ‘best practice’ to continuously develop this policy and our processes

MACVAD expects that suppliers of goods and service providers adopt policies and procedures consistent with the above