TOA Global Anti-Human Trafficking and Modern Slavery Policy
TOA Global and its affiliates and subsidiaries (“TOA”) are committed to maintaining the highest standards of business conduct and ethics everywhere we operate or do business. This includes a strong commitment to respect human rights and take proactive steps to prevent forced labor, human trafficking, sexual exploitation, and other forms of modern slavery within our own business and supply chain.
Through this Anti-Human Trafficking and Modern Slavery Policy (“Policy”), we communicate our values and expectations, setting a high standard for ourselves and our partners, ensuring that we do not tolerate any form of modern slavery.
While this Policy is designed to provide guidance, it may not cover every possible scenario. Employees and partners should seek advice from TOA’s Legal Team if uncertain about any action that might violate this Policy.
Scope
Policy Statement
Our approach includes:
- Prevention: Avoiding activities, practices, or conduct that might lead to or constitute modern slavery within TOA’s operations or supply chain.
- Compliance: Adhering to all applicable laws and regulations, including the Modern
Slavery Act 2018 (Cth). - Reporting: Encouraging and facilitating reporting of actual or suspected modern slavery to TOA’s Legal Team, HR Team, or other appropriate channels.
- Risk Assessment: Regularly investigating and assessing the risks of modern slavery in our business and in relation to our suppliers and other business partners.
- Due Diligence: Conducting due diligence on our suppliers and other business
partners to ensure they comply with ethical employment practices and anti-slavery
laws
Communication and Awareness of this Policy
To maintain awareness and understanding of modern slavery risks, TOA commits to:
- Publishing this Policy on our website and other appropriate platforms.
- Providing training to employees on this Policy and modern slavery risks during onboarding and periodically thereafter.
- Communicating this Policy to all individuals and organizations working for or with TOA at the outset of the business relationship and reinforcing expectations as necessary
Reporting Mechanisms
All employees, contractors, business partners, and other stakeholders are encouraged to report suspected violations of this Policy. Reports can be made to:
- TOA’s Legal Team
- Your supervisor or another manager
- The HR Team
Reports may also be submitted anonymously via TOA’s Speak Up platform in Luna.
Reports will be treated confidentially and used solely for investigation purposes. TOA will take appropriate measures to protect the identity of individuals making reports, sharing information only on a need-to-know basis with authorized personnel.
Responsibility, Review, and Remediation
TOA’s Legal Team is responsible for overseeing the implementation and adherence to this Policy. The Legal Team will review the Policy periodically to ensure its effectiveness and relevance, making updates as necessary.
In cases where violations are identified, TOA will take appropriate remedial actions, including supporting affected individuals and addressing systemic issues to prevent recurrence