Introduction
Think Creative Agency (Australia) Pty Limited ABN 47159080369, registered office Level 4, 56 Neridah Street, Chatswood, NSW, 2067, one of Australia’s leading full service branding and marketing agency, recognises that all businesses have an obligation to prevent slavery, slavery-like practices and human trafficking and will do all in its respective power to prevent slavery, slavery-like practices and human trafficking within its business and within the supply chains through which it operates.
This statement addresses Think Creative Agency’s obligations and compliance in relation to the ‘Modern Slavery Act 2018 (Cth)’ (‘the Act’) and applicable state legislation and highlights the steps we take to ensure there is no slavery or human trafficking occurring within the organisation or its supply chains. One of our company’s most valuable assets has always been its reputation for integrity and fairness. Maintaining this reputation within our market is an essential pre-requisite to our continued success.
Modern slavery can take many forms including the trafficking of people, forced labour, child labour, servitude and slavery. As a leading marketing agency, we take our responsibility for seriously and are aware of the potential for being targeted by traffickers and unlicensed labour hire providers, in local jurisdictions where licensing is a requirement. Our own processes around candidate engagement ensure our employees are alert to the signs of exploitation, so that we may take the necessary action promptly and effectively should it be identified. Sectors affected include, but are not limited to, construction & property, engineering & manufacturing and health & social care.
Think Creative’ supply chains & risks of Modern Slavery
Suppliers to Think Creative
We contract with third parties who provide services to assist with the everyday running of our business, such as IT service providers and property management companies (who, for example, may provide cleaning services to our offices) as well as companies who provide office supplies to our office network.
We acknowledge that by virtue of contracting with other parties, whether as a client or as a supplier, there is always some risk that may contribute to modern slavery practices. We expect our suppliers and potential suppliers to aim for high ethical standards and to operate in an ethical, legally compliant and professional manner by adhering to the Think Creative Code of Conduct. We also expect our suppliers to promote similar standards in their own supply chain.
Actions taken to assess and address modern slavery risks
Think Creatives ensures that strict compliance checks are carried out for all candidates it supplies. We verify the identity of each worker and their right to work before supply commences. We also have a dedicated temporary worker payroll team who audit the relevant modern award or enterprise agreement that a temporary worker is engaged under to ensure they are paid correctly in accordance with the relevant award or agreement.
As part of our commitment to identify and eradicate slavery and human trafficking and to continuously assess and address modern slavery risks, we have in place a process to undertake due diligence on our supply chain network to ensure compliance with legislative obligations, and such compliance forms part of our contractual relationship with suppliers. We will use best endeavours to procure from our suppliers by contract that full compliance with the Act must be achieved. We will use best endeavours to separately require that any actual or potential risk of breaching the Act that suppliers identify in their own operations or supply chains are communicated to us. This information will be assessed and evaluated appropriately by senior members of Think Creative management on an ongoing basis.
Think Creative created a Supplier Code of Conduct that is relevant to all suppliers to Think Creative. Suppliers are expected to adhere to the Think Creative Code of Conduct, which includes specific reference to various matters including human rights, anti-bribery and corruption, and modern slavery and human trafficking, and suppliers should have in place a policy recognising, respecting and protecting the human rights of their employees, those of their suppliers and business partners and the communities affected by the suppliers’ operations.
Think Creative’ position, which is mirrored in its Supplier Code of Conduct, is that:
- Employees should be free to choose to work for their employer and to leave the company upon reasonable notice.
- All employees must be provided with a clear contract of employment, which complies with local legislation.
- All employees must be treated in a fair and equal manner and with dignity and respect.
- Any form of discrimination, victimisation or harassment on any prescribed grounds under commonwealth, state or territory laws should be prohibited. This includes marital status, pregnancy, family responsibilities, sex (including gender reassignment), race (including colour, ethnic and national origin, nationality), disability, sexual orientation, religious belief, age, trade union activity or any other prescribed ground
- All applicable laws and industry standards on employee wages, benefits, working hours and minimum age should be adhered to in all countries of operation, without any unauthorised deductions.
- All slavery and human trafficking laws must be complied with including, but not limited to, the provisions of the Act and any applicable state legislation. Suppliers must ensure their business operations are free from slavery and human trafficking practices whether in Australia or elsewhere, both internally and within their supply chains and other external business relationships.
- Cooperation with client due diligence.
Our clients in the private sector operate in many industries and range in size from small businesses through to local subsidiaries of global groups. We also work closely with government departments and agencies across all jurisdictions.
Think Creative engaged with various companies that provide cleaning services to Think Creative’ office. This involved providing copies of Think Creative’ Supplier Code of Conduct to these suppliers and enquiring as to the modern slavery compliance practices and procedures.
All Think Creative employees have access to dedicated channels through which they may voice concerns, either through local reporting mechanisms or through whistleblowing procedures. Think Creative is committed to protecting employees when disclosing malpractice and will ensure that all disclosures made in compliance with whistleblowing procedures will be treated confidentially and without fear of retaliation. It is by receiving and evaluating feedback and maintaining a culture of compliance that Think Creative can assess the effectiveness of its practices and procedures.
All staff within Think Creative are expected to comply with all laws and act in accordance with local guidelines and regulations and act with integrity and honesty. We have undertaken to review our policies and procedures to ensure our colleagues have access to any additional information and support they may require with regard to human trafficking, forced labour, child labour, servitude and slavery. All relevant employees in Australia will undertake training on modern slavery and human trafficking and this training is available to all employees to undertake.
We will undertake continuous and ongoing assessment of our supply chains by evaluating information that we receive from our suppliers and to promptly act on allegations or findings of involvement in such practices.
We will also set up an annual review process whereby members of senior management will review our policies and procedures and our response to modern slavery.
Think Creative will continue to assess ways to reduce the risks of modern slavery and some steps to be taken will include:
- Publish Think Creative’ Supplier Code of Conduct
- Publish changes made to Think Creative’ standard form contracts
- Following the engagement with the commercial cleaners of a Think Creative offices, engage with various suppliers of firstly, IT products and services, and secondly, office supplies, to the Think Creative office to assess their modern slavery policies and processes.
- Increase the number of Think Creative employees who are provided with dedicated training on modern slavery laws.
- Set up an annual review process with members of senior management.
