Modern Slavery Policy
Transport & Charter Operations — Australia | Sydney Charter Bus Pty Ltd
| Issued by | Sydney Charter Bus Pty Ltd (trading as Sydney Charter Bus Australia) | ABN: 44 134 888 912 |
| Accreditation | NSW Accreditation No. 39461 — Transport for NSW |
| Applies to | All employees, contractors, subcontractors, suppliers and third-party providers |
| Legislative framework | Modern Slavery Act 2018 (Cth) | Criminal Code Act 1995 (Cth) | Fair Work Act 2009 (Cth) |
| Review | Reviewed annually or as required — current version always published at www.sydneycharterbus.com.au/company-policies |
Purpose
This policy establishes the commitment of Sydney Charter Bus Pty Ltd (“the Company”) to identify, prevent and address risks of modern slavery within its operations and supply chains. The Company adopts a zero-tolerance approach to modern slavery and is committed to ethical, lawful and transparent business practices across all areas of operation.
Scope
This policy applies to:
| All employees — full-time, part-time and casual |
| Bus and coach drivers (including subcontractors) |
| Depot, cleaning and yard staff |
| Mechanics and maintenance personnel |
| Office staff and management |
| Suppliers, contractors, subcontractors and third-party providers |
Legislative Framework
This policy aligns with applicable Australian laws, including:
| ◆ | Modern Slavery Act 2018 (Cth) |
| ◆ | Criminal Code Act 1995 (Cth) — Divisions 270 & 271 |
| ◆ | Fair Work Act 2009 (Cth) |
| ◆ | Applicable NSW and Commonwealth regulations |
Definition of Modern Slavery
Modern slavery refers to serious exploitation where individuals cannot leave or refuse work due to coercion, threats or deception. This includes:
| Human trafficking | The recruitment, transportation, transfer, harbouring or receipt of persons through coercion, deception or force for the purpose of exploitation. |
| Forced labour | Work extracted from a person under threat, coercion or penalty where the individual has not offered themselves voluntarily. |
| Debt bondage | The use of debt as a mechanism to control or compel a person to work, often at inflated or manufactured cost. |
| Servitude | A condition in which a person is compelled to work for another, with their freedom severely restricted. |
| Child labour | The employment of children in work that is harmful to their health or development, or that deprives them of education. |
| Forced marriage | A marriage entered into without the free and full consent of one or both parties, often through coercion or deception. |
Policy Statement
Sydney Charter Bus Pty Ltd:
| ✓ | Prohibits all forms of modern slavery and exploitation without exception |
| ✓ | Will not knowingly engage with suppliers or contractors involved in unethical labour practices |
| ✓ | Maintains lawful employment practices across all operations |
| ✓ | Actively identifies and mitigates modern slavery risks within its operations and supply chains |
Risk Areas in Transport Operations
Recognised risk areas within our transport operations include:
| Subcontracted drivers & labour hire | Use of subcontracted drivers or labour hire arrangements where employment conditions, wages and working hours may not be directly visible to the Company. |
| Depot cleaning & yard services | Cleaning and yard maintenance services engaged through third-party contractors where labour practices may be difficult to monitor. |
| Vehicle maintenance & supply chains | Parts, components and maintenance services sourced through supply chains that may include offshore or high-risk manufacturing environments. |
| Uniforms, parts & imported goods | Procurement of uniforms, safety equipment and imported goods where ethical sourcing standards may not be formally verified. |
| Temporary or migrant labour | Engagement of temporary or migrant workers where vulnerability to exploitation, wage theft or coercive conditions may be elevated. |
Responsibilities
| Management |
| Enforce this policy across all operations |
| Conduct risk assessments on operations and supply chains |
| Ensure compliance obligations are met across the organisation |
| Employees & Contractors |
| Comply with lawful workplace practices at all times |
| Report suspected risks or breaches immediately upon identification |
| Administration & Procurement |
| Undertake supplier due diligence prior to and during engagement |
| Maintain compliance records and audit documentation |
Due Diligence & Risk Management
The Company will:
| ✓ | Assess suppliers and contractors prior to engagement for modern slavery risks |
| ✓ | Require written compliance declarations from all suppliers and contractors |
| ✓ | Monitor high-risk suppliers on an ongoing basis throughout the period of engagement |
| ✓ | Take corrective action where modern slavery risks or breaches are identified |
Reporting & Whistleblower Protection
All personnel must report suspected modern slavery risks immediately upon identification. Failure to report may constitute a breach of this policy.
The Company:
| ✓ | Provides confidential reporting channels for all personnel |
| ✓ | Protects individuals from retaliation for good-faith reporting |
| ✓ | Investigates all reports thoroughly and takes appropriate remedial action |
|
To Report a Concern All reports are treated confidentially. Individuals who make a report in good faith are protected from any form of retaliation under this policy. |
Training & Awareness
The Company will:
| Provide training to all relevant personnel on modern slavery risks, indicators and reporting obligations |
| Promote awareness of modern slavery risks across the organisation and supply chain |
| Ensure procurement staff and management understand and fulfil their obligations under this policy |
Compliance & Breach
Non-compliance with this policy may result in:
| ! | Disciplinary action up to and including summary dismissal |
| ! | Termination of employment or contract without notice |
| ! | Referral to regulatory authorities and law enforcement where required by law |
Role-Specific Obligations & Controls
| Role | Requirements | Controls | Risk Indicators |
|---|---|---|---|
| Bus Drivers (Employees & Subcontractors) | Lawful engagement under Australian workplace laws. No coercion, unlawful deductions or exploitative conditions. Mandatory reporting of suspicious passenger or labour situations. Subcontractors must hold valid ABN, insurance and compliance documentation. | Verification of ABN, insurance and licence documentation. No use of undocumented or exploited labour. | Excessive working hours. Informal or cash-based payments. Signs of coercion or dependency. |
| Depot Staff | Engagement through lawful employment or compliant labour hire providers. Fair wages and safe conditions at all times. | Labour hire provider verification. Monitoring of work conditions and hours. | Restricted communication. Third-party control of workers. Lack of payslips or documentation. |
| Mechanics & Maintenance | Lawful employment or contractor engagement. Ethical sourcing of parts and maintenance services. | Supplier due diligence. Preference for transparent and traceable supply chains. | Untraceable or unusually cheap parts. Non-compliant or unverified suppliers. |
| Office Staff | Supplier vetting and compliance checks. Contractual enforcement of ethical standards. Monitoring of procurement risks. | Compliance documentation review. Contractual modern slavery clauses. | Missing supplier documentation. Refusal to provide compliance assurances. |
| Subcontractors & Third Parties | Compliance with all applicable Australian laws. Written acknowledgment of this policy. Provision of ABN, insurance and evidence of lawful employment practices. | Company retains audit rights. Suspension or termination for policy breaches. | Unwillingness to provide documentation. Refusal of audit requests. |
Monitoring, Auditing & Continuous Compliance
Internal Monitoring
- Regular review of workforce practices, hours, wages and conditions
- Monitoring of payroll and contractor payment records
- Maintenance of auditable records in accordance with Australian law
Supplier & Subcontractor Auditing
- Right to audit high-risk suppliers and subcontractors
- Verification of labour practices and documentation
- Enforcement of corrective actions where required
Risk-Based Priority Focus
- Labour hire and cleaning services
- Depot and yard operations
- Offshore supply chains
- New suppliers and contractors
Continuous Improvement
- Annual policy updates aligned to legislative changes
- Adoption of industry best practice
- Integration of stakeholder feedback into policy review
Record Keeping
- Records maintained in accordance with applicable Australian law and regulatory requirements
Governance
- Senior management oversight of compliance, enforcement and reporting obligations
Policy Effectiveness Measured By
- Risk reduction outcomes across operations and supply chains
- Supplier compliance rates
- Incident and reporting outcomes
- Internal and external audit results
Modern Slavery Statement
Where required under the Modern Slavery Act 2018 (Cth), the Company will publish an annual Modern Slavery Statement addressing:
| A description of the Company’s operations and supply chains |
| The modern slavery risks identified within those operations and supply chains |
| Actions taken to assess and address those risks |
| An assessment of the effectiveness of measures implemented |
Integration with Company Policies
This policy must be read in conjunction with the following Company policies and documents:
| ◆ | Driver Code of Conduct |
| ◆ | Workplace Health & Safety (WHS) Policies |
| ◆ | Procurement Policies |
| ◆ | Contractor Agreements and Subcontractor Compliance Documentation |
🚫 Policy Compliance Notice
This policy forms part of the employment, contractor and supplier agreements of Sydney Charter Bus Pty Ltd. All personnel, contractors and suppliers are required to comply with this policy as a condition of their engagement. Sydney Charter Bus Australia reserves the right to amend this policy at any time in accordance with changes to the Modern Slavery Act 2018 (Cth) and applicable Australian legislation. The current version is always published at www.sydneycharterbus.com.au/company-policies.
📞 1300 468 199 | 📱 0413 182 999 | ✉ [email protected]