Modern Slavery Statement
Brainbox is not a mandated organisation for the purposes of compliance with the Modern Slavery Act 2018 (Cwth) and is not strictly required to submit a Modern Slavery Statement. Rather, Brainbox has elected to voluntarily comply with the provisions of the Act and its supporting Regulations because we are convinced that the Act is aligned with our organisational value and is the ‘right’ way to conduct our business.
Our corporate value of Always Be Kind means that we are committed to facilitating workspaces and relationships that are safe, ethical and transparent. We strive to not pursue relationships that facilitate, endorse or encourage modern slavery practices, whether directly or indirectly.
Our anti-slavery commitments include:
- Operating in accordance with the Modern Slavery Act 2018 (Cth)
- Ensuring our people understand modern slavery and the risk it presents to our operations
- Providing our people with appropriate avenues for reporting potential instances of modern slavery within our operations
- Mitigating modern slavery risk within our operations
- Eliminating potential and/or actual modern slavery practices from our operations and our supply chain
- Ensuring appropriate transparency with our people, clients, suppliers and stakeholders regarding the maturity of our modern slavery due diligence process and the findings arising from this
How We Do It
After consideration of our operations and supply chain, we have classified our modern slavery risk into two distinct areas: our clients and our people.
We take great pride in providing services to a diverse client base, some of whom may be attracted to our business model for reasons other than just the benefits of culture and currency arbitrage. This may place us at risk of unwittingly entering into an relationship with a client who does not share the same commitment to preventing or abstaining from modern slavery practices. For this reason, we have classified the risk of modern slavery in our client base as moderate.
Brainbox employs dedicated HR Managers and Client Engagement Managerswith a specific remit to remain vigilantfor any practices that contrary to our anti-slavery commitments. These personnel are trained in our policies, procedures and controls in order to be able to effectively identify client conduct that may contravene these commitments. Further, the majority of our key clients are primarily domiciled in Australia (a low-risk jurisdiction).
The knowledge, skills and integrity of our people is paramount to our continued success as a business. In assessing the risk of modern slavery within our direct workforce, we have considered our recruitment, retention, remuneration and employment practices, as well as the nature of our workforce generally.
By virtue of our extensive internal policy framework and an inherently skilled workforce, we have classified the risk of modern slavery in relation to our people as low.
Brainbox’s stringent recruitment and employment practices reflect our core value, and the risk of Brainbox actively participating in or contributing to modern slavery through our people is low.
A number of items have been considered through the due diligence process, including but not limited to:
- Standard Conditions of Employment
- Remuneration Scheme (including benefits)
- Recruitment Process
- Transfers and Secondments
- Performance Management Framework
- People Management Framework
- Policies, Procedures and Programs
- Bullying, Discrimination, Harassment and Victimisation Policy
- Whistleblowing Facilities
- Employee Assistance Program
Brainbox has an extensive policy framework covering the risks associated with our people.
This in turn provides confidence in the quality of our people, who are well- educated and professionally trained, and reinforces the belief that our people pose little risk of modern slavery.
Brainbox welcomes external inspection or audit of any of the commitments or elements discussed in this Statement.