Modern Slavery Policy

Modern Slavery Policy

Modern Slavery Policy

1.0 Purpose

This policy sets out Ventura’s position against human trafficking and modern slavery.

2.0 Scope

This policy applies to all Ventura companies, employees within Ventura and we expect contractors, subcontractors and suppliers to apply similar standards.

3.0 Principles

Ventura is committed to acting ethically and with integrity and transparency in all business practices.

Ventura respects ethical labour practices and values and promotes diversity. Consistent with these principles, Ventura takes a zero tolerance approach to any form of human rights abuses as defined by the Commonwealth Modern Slavery Act 2018 in its operations or supply chain. Modern slavery describes the most serious forms of exploitation including trafficking in persons, slavery, servitude, forced marriage, forced labour, debt bondage, deceptive recruiting for labour or services; and the worst forms of child labour.

All employees, contractors, sub-contractors and suppliers must not engage in any practices of modern slavery or human trafficking. This includes:

  • using deceptive or coercive practices during recruitment or employment, such as making
  • material misrepresentations about the key terms and conditions of employment;
  • procuring commercial sex acts;
  • destroying, concealing, confiscating or otherwise denying access to any employee’s identity or immigration documents (for example passports or drivers’ licenses);
  • providing or arranging housing that fails to meet host country housing and safety standards;
  • employing any child under the age of 15;
  • using forced labour in the performance of any contract;
  • failing to provide an employee contract, recruitment agreement or other required work document in writing (where one is required by law);
  • using recruiters or suppliers that do not comply with local labour laws; and
  • charging employees recruitment fees.

Policy Breaches

All suspected breaches will be investigated, and appropriate disciplinary and remedial action taken. Employees who do not strictly comply with this policy may face disciplinary action, including formal warnings and termination.


Modern Slavery Policy
PO611 Version:1 6th January 2021

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