About this statement

This statement sets out the steps Blac Blok [legal entity, ABN] takes to identify and address the risk of modern slavery in our operations and supply chains. Modern slavery includes forced labour, debt bondage, servitude, human trafficking, forced marriage and the worst forms of child labour.

Our structure, operations and supply chains

We’re an Australian debt collection agency operating from [location] with [number] staff. We recover overdue accounts for Australian businesses. We don’t manufacture, import or sell goods.

Our supply chain is small and service-based: software and IT hosting, telecommunications, office premises and cleaning, printing and mail, professional services, and office supplies.

Risks of modern slavery

The risk in our direct operations is low. Our staff are employed in Australia under the Fair Work Act 2009 (Cth), paid at or above lawful rates, and free to leave their employment.

The more realistic risks sit deeper in our supply chain:

• manufacturing of IT hardware and electronics, often in offshore facilities
• cleaning and property services, where subcontracting and vulnerable or migrant labour are
  common
• printing, promotional items and office consumables
• offshore data processing or call handling, if ever used

We also recognise a risk specific to our industry: debt bondage. Financial pressure on a person can be exploited by others. Where our staff identify indicators of exploitation, coercion, trafficking or family violence in dealing with a debtor, they must escalate the matter to a supervisor, and collection on the account is paused.

What we do about it

• We apply a supplier code of conduct requiring suppliers to comply with labour laws and to
  prohibit forced and child labour
• We assess modern slavery risk when engaging new suppliers, with closer scrutiny of cleaning, IT
  hardware and any offshore service
• We favour suppliers who can show their own modern slavery reporting or credible assurance
• Our staff are trained to recognise indicators of modern slavery, including in contact with
  debtors, and to escalate concerns
• Our whistleblower and complaints channels can be used to raise concerns confidentially
• Where we find a problem, our first response is remediation with the supplier rather than
  immediate termination, so that affected workers aren’t left worse off

How we measure whether this is working

• Proportion of material suppliers who have accepted our supplier code of conduct
• Number of suppliers risk-assessed during the period
• Staff completion of modern slavery awareness training
• Number of concerns raised, and how each was resolved

We review these annually and report the results in the following statement.

Consultation

Blac Blok does not own or control any other entities, so no consultation with owned or controlled entities was required.

Approval

This statement was approved by [the board or the principal] of Blac Blok on [date] and is signed by [name, position].