Modern Slavery Statement
Oct 2024
This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015, the Australian Modern Slavery Act 2018, and other applicable global standards such as the United Nations Guiding Principles on Business and Human Rights (UNGPs) and the International Labour Organization (ILO) Conventions. It outlines the steps taken by Jungal Pty Ltd and its subsidiaries (collectively referred to as “Jungal Pty Ltd” or “Jungal”) to address the risks of modern slavery, human trafficking, and forced labour within our business operations and supply chains for the financial year 1 January 2022 to 31 December 2022.
Jungal Pty Ltd takes a zero-tolerance approach to any form of modern slavery, human trafficking, or labour exploitation. We are committed to upholding the highest standards of transparency, ethics, and integrity across our operations, aligned with international human rights standards.
Our Approach
Jungal Pty Ltd operates in line with global human rights frameworks, including the UNGPs, ILO Core Labour Standards, and relevant national modern slavery laws. We ensure compliance with legal, regulatory, and ethical standards across all aspects of our business, including our relationships with customers, contractors, vendors, and employees.
Vendors
Our Procurement and Legal teams work together to manage risks related to modern slavery and human trafficking within our supply chains. Jungal’s Modern Slavery Code of Conduct, publicly available on our website, defines the ethical standards expected from our customers, contractors, and vendors. We seek to impose contractual obligations on our vendors to comply with these standards and include clauses to address potential breaches in supply contracts.
Vendors are regularly assessed based on their alignment with international labour laws and human rights conventions, particularly those outlined by the ILO. We prioritise suppliers that operate in low-risk jurisdictions or have strong policies mitigating the risk of forced labour.
Employees
Jungal Pty Ltd ensures that our recruitment and employment practices are in full compliance with ILO standards and applicable national laws, including stringent pre-employment screening, such as right-to-work checks and reference verification. Employees undergo an induction that highlights our Anti-Slavery and Human Trafficking Policy, enabling them to identify and report any concerns. Our whistleblower mechanism ensures a confidential channel for employees to raise concerns relating to modern slavery.
All Jungal employees are expected to uphold our Anti-Bribery and Corruption Policy, with a clear stance on integrity, transparency, and accountability.
Customers
In our Code of Ethics, we emphasise our commitment to ethical business practices. We expect our customers to align with our values of integrity and respect for human rights. We actively avoid partnerships with businesses whose practices involve forced labour, child labour, or any form of exploitation, as these represent serious violations of our ethical standards.
Jungal Pty Ltd Policies
Jungal Pty Ltd has robust policies to identify and prevent modern slavery, forced labour, and human trafficking. Our policies are underpinned by international frameworks, including the ILO Conventions on Forced Labour (No. 29) and Abolition of Forced Labour (No. 105). All employees are governed by these policies and receive guidance on their role in preventing human rights violations.
Due Diligence and Risk Assessment
We conduct comprehensive due diligence on all prospective vendors, contractors, and customers, ensuring alignment with our ethical standards. Jungal Pty Ltd identifies sectors and regions that may be vulnerable to modern slavery using the following risk indicators:
- Reliance on low-skilled or migrant labour
- Presence of child labour
- Hazardous working conditions
- Locations with weak governance, poor human rights enforcement, or high corruption
Jungal’s operations, being primarily online, minimise exposure to higher-risk sectors. However, we maintain a vigilant approach by conducting regular risk assessments on gig workers (“Gigstars”) to verify their compliance with local employment laws and human rights standards through independent certification.
Continuous Improvement and Accountability
We are committed to continuous improvement in addressing the risks of modern slavery across our operations. Our actions include:
- Vendor Audits: We seek the contractual right to audit suppliers and contractors at our discretion, particularly those in higher-risk regions, and ensure that they adhere to ethical treatment standards as outlined in our Modern Slavery Code of Conduct.
- Training and Awareness: All employees involved in recruitment and procurement receive modern slavery-specific training to help them identify and manage risks. This includes recognising potential signs of forced labour and implementing the requirements of global modern slavery laws.
- Vendor Agreements: We ensure all vendor contracts include an ethical treatment clause, especially for suppliers operating in high-risk locations, to guarantee their labour practices comply with international human rights standards.
Should a vendor or contractor fail to meet our expectations, or be unwilling to take corrective action, Jungal Pty Ltd will terminate the relationship.
Further Steps
Jungal Pty Ltd remains focused on enhancing the measures we take to prevent modern slavery and human trafficking. We will continue to:
- Strengthen our due diligence processes to better identify risk factors and mitigate potential human rights violations.
- Regularly review and update our policies to align with evolving international standards and legislation.
- Engage with stakeholders to raise awareness of modern slavery risks across our supply chain and the broader business community.