Modern Slavery Policy

1. Introduction

At Thirst Creative, our business operations are built on a foundation of respect for individual rights and human dignity. We understand the importance of conducting our activities responsibly and ethically.

Recognising that modern slavery is a gross violation of fundamental human rights, we have adopted a zero-tolerance approach towards it in all forms within our operations and supply chains. We are committed to doing our part to eradicate these practices.

This statement outlines our policies and processes designed to prevent and mitigate modern slavery risks throughout our company and our business relationships. It is not a mere declaration, but a commitment to continuously improving our business practices to ensure they are as ethical, efficient, and responsible as possible.

We acknowledge the Australian Government's ongoing review of the Modern Slavery Act 2018 (Modern Slavery Act) and are committed to ensuring our operations are in alignment with this directive, and any other efforts aimed at the abolition of modern slavery.

We believe that through collaboration and awareness, we can make a meaningful contribution to the global fight against modern slavery. We are ready to face the complexities of this issue head-on and pledge to use our creativity and efficiency in navigating this challenge.

2. Scope

This policy applies to all persons working for or on behalf of Thirst Creative, in any capacity, including employees, directors, officers, agency workers, volunteers, contractors, consultants, and business partners.

3. Definitions

To ensure a clear understanding of our policy, we have defined the following terms as they are used in the context of modern slavery and our business operations.

• Modern slavery encompasses slavery, servitude, forced labour, debt bondage, and human trafficking. These are situations where individuals are deprived of their freedom and are exploited for personal or commercial gain.
• Child labour is work that deprives children of their childhood, potential and dignity, and is harmful to physical and mental development. It refers to work that is mentally, physically, socially or morally dangerous and harmful to children and/or interferes with their schooling by depriving them of the opportunity to attend school, obliging them to leave school prematurely, or requiring them to attempt to combine school attendance with excessively long and heavy work. The term "child" refers to a person below the age of 18.
• Commercial sex act is defined as any sex act for which anything of value is given to or received by any person.
• Debt bondage describes situations where the victim’s services are pledged as security for a debt and the debt is clearly excessive or the victim’s services are not applied towards paying off the debt, or the length and nature of the services are not limited and defined.
• Deceptive recruiting for labour services refers to situations where the victim is deceived about whether they will be exploited through a type of modern slavery.
• Due diligence is the process an organisation undertakes to identify, prevent, and mitigate any negative impacts on human rights, including slavery and human trafficking, within its operations and supply chain.
• Forced labour describes situations where the victim is either not free to stop working or not free to leave their place of work.
• Forced marriage describes situations where coercion, threats or deception are used to make a victim marry or where the victim does not understand or is incapable of understanding the nature and effect of the marriage ceremony.
• Migrant worker refers to people who leave home to find work outside of their hometown or home country. This term includes both foreign and domestic (internal) migrant workers.
• Recruiter refers to both private and public entities that offer labour recruitment services.
• Servitude describes situations where the victim’s personal freedom is significantly restricted and they are not free to stop working or leave their place of work.
• Slavery describes situations where the offender exercises powers of ownership over the victim, including the power to make a person an object of purchase and use their labour in an unrestricted way.
• Supplier is an organisation or person that provides a product or service used in our supply chain.
• Supply chain is a sequence of activities or parties that provides products or services to the organisation.
• Trafficking in persons refers to the recruitment, harbouring and movement of a person for exploitation through modern slavery.
• Training is designed to help workers better understand organisational policies, effectively implement them, identify and respond to potential modern slavery risks, and foster a workplace that promotes respect for human rights.
• Worker is a person who performs work, including seasonal, contract and other temporary labour. Both employees and independent contractors are considered workers.
  

4. Responsibilities

The responsibility for ensuring the implementation and compliance of this policy lies with the Management team of Thirst Creative.

5. Expectations

At Thirst Creative, we expect all individuals and entities associated with us, including employees, suppliers, and business partners, to uphold the principles outlined in this policy and to maintain a zero-tolerance approach to modern slavery. This includes compliance with all relevant laws and regulations, being vigilant in observation, and promptly reporting suspicious activities or breaches of this policy. We also expect a commitment to continual improvement and learning, as part of our collective effort to combat modern slavery. We commit to a non-retaliation policy for voicing concerns or reporting potential cases of modern slavery.

6. Due Diligence and Risk Assessment

We employ thorough due diligence and risk assessment to identify, assess, and manage potential risk areas related to modern slavery in our operations and supply chains. This process involves identifying potential risk areas, assessing their impact and likelihood, implementing strategies to manage these risks, ensuring vendor compliance with our policy, and continuously reviewing and improving our risk management processes. By doing this, we aim to proactively prevent any occurrences of modern slavery within our sphere of influence.

7. Training and Education

We believe in the power of ongoing training and education in combating modern slavery. All new hires receive initial training on modern slavery as part of their onboarding, followed by comprehensive annual refreshers. The training is delivered by knowledgeable and competent personnel and can be conducted in person, online, or through a combination of both methods depending on the needs and circumstances of the workers. This dynamic approach ensures all staff are informed about the latest best practices and are equipped with the knowledge to identify and report any suspected breaches of our policy. The training covers a range of topics including the Modern Slavery Act 2018 (Cth), our policy, the risks of modern slavery, and practical guidance on identifying and reporting suspected incidences.

8. Reporting Mechanisms

Thirst Creative is committed to ensuring an open and transparent culture where concerns about potential ethics, human rights, legal, or regulatory violations can be raised without fear of retaliation. This includes improper or unethical business practices such as fraud, bribery, or any form of modern slavery.

We encourage anyone, including employees, contractors, clients, and other third parties, to report any such issues or concerns in good faith.

1. Internal Reporting - If an employee, contractor, or other internal party has a concern, they should raise it directly with the head of their department. Our department heads have the responsibility to respond to these reports promptly and appropriately.

2. General Manager - If for any reason, an internal party is uncomfortable addressing the issue with their department head or feels their concern is not being adequately addressed, they may escalate the matter directly to the General Manager.

3. External Reporting - Clients, suppliers, business partners, and other external parties are also encouraged to report any concerns or suspected breaches of our modern slavery policy. They can do so by contacting the General Manager directly or by emailing studio@thirstcreative.com.au.

Regardless of the reporting channel, all reports will be treated as confidential and will be thoroughly investigated to determine an appropriate course of action. We maintain a strict non-retaliation policy and will ensure that no one suffers any adverse treatment as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of our organisation or in any of our supply chains.

9. Response and Remediation

In our commitment to ensuring a business free of modern slavery, we take all reports of potential violations seriously. Our response and remediation process is designed to ensure fairness, transparency, and prompt action.

1. Investigation - Upon receiving a report of a potential violation, we will launch a thorough and objective investigation, overseen by the appropriate department head and the General Manager, as required. We ensure confidentiality and non-retaliation throughout the investigative process. We will also cooperate fully with any external investigations or audits.

2. Corrective Actions - If a violation is identified, we take swift and decisive action, including immediate rectification, development of a corrective action plan, or engagement of third-party auditors or consultants.

3. Contractual Consequences - If a violation involves a supplier or business partner, we reserve the right to renegotiate or terminate our contract with that party. We also work collaboratively with them to address the issue in their operations and supply chains.

4. Legal Reporting - If the investigation reveals illegal activities, we will report these instances to the relevant authorities as required.

5. Remediation - If we have caused or contributed to modern slavery, we are committed to taking steps to rectify the situation. This may include providing appropriate support to those affected, making changes to our operations and practices, or working with our partners and stakeholders to ensure the conditions leading to such violations are addressed and eliminated. The specific actions taken will be determined on a case-by-case basis, in accordance with the nature and severity of the violation.

Our ultimate goal is not merely to respond to incidents of modern slavery but to prevent them from occurring in the first place. To this end, we will use any identified violations as an opportunity for learning and improving our practices, striving for continuous progress in our commitment to combat modern slavery.

10. Review

This policy will be reviewed annually and may be amended as necessary.