Introduction
This Modern Slavery Policy (the “Policy”) sets out how Agile Underwriting Services Pty Ltd, Insurance Service Holdings Pty Ltd (ISH), Agile Insurance Group NZ Limited and Agile Risk Management Ltd (collectively referred to as “Agile”) demonstrate commitment to tackling the problem of modern slavery in supply chains. We recognise modern slavery as a serious violation of human rights and are dedicated to identifying and eliminating the risk of modern slavery and human trafficking in our operations and supply chains in accordance with the Modern Slavery Act 2018 (Cth).
Scope
This policy applies to:
- All employees, officers and directors of the Company
- Contractors, suppliers, agents, and other third parties with whom we do business
Our Business
While we operate in a low-risk sector for modern slavery, we acknowledge that risks may exist in indirect operations, particularly in supply chains involving:
- Business process outsourcing
- Cleaning, maintenance, and facility services
- IT, software development and support services
- Office equipment and apparel
Our Commitment
We are committed to:
- Upholding fundamental human rights and complying with the Modern Slavery Act
- Integrating human rights and modern slavery considerations into procurement and risk management processes
- Engaging with suppliers on ethical practices and responsible sourcing
- Investigating any reports of suspected modern slavery and taking corrective action as needed
- Work collaboratively with our supply chain partners to uphold high standards of conduct around safe working conditions, and acting fairly and ethically.
Identifying and Managing Risk
Our procurement process includes the vetting of new suppliers and risk analysis of all suppliers. We assess the risk of modern slavery in our operations and supply chains through:
- Risk mapping and categorisation of suppliers by sector, geography and service type
- Due diligence and onboarding assessments
- Supplier questionnaires and self-assessment declarations
- Ongoing contract management and audit rights
Where modern slavery risks are identified, we work with suppliers to remediate and improve practices or terminate relationships if necessary.
Employees
We respect the rights of everyone who works for us and with us and treat our employees with compassion. This also extends to the employees of suppliers working with us.
Our employee handbook applies to all employees and covers topics relevant to a safe and secure working environment and ensuring that employees have a means of communicating any concerns.
This is supported by our Compliance Framework which outlines the whistleblowing protocols in place.
Roles and Responsibilities
- The Board of Directors provides oversight and governance on modern slavery risk
- The Management Committee is responsible for policy implementation
- The Risk Management and Compliance Department manages risk assessments and reporting
- All employees must comply with this policy and report any suspected breaches.
Training and Awareness
We ensure that employees involved in procurement, supplier management and HR are knowledgeable about the risks associated with supply chains such that they can:
- Recognise indicators of modern slavery
- Understand due diligence processes
- Act on concerns or disclosures appropriately
Reporting Concerns
We encourage anyone (internal or external) to report suspected modern slavery via our Whistleblower Policy or through designated reporting channels. All reports are treated seriously and investigated in line with our risk and compliance procedures.
Monitoring and Review
This policy is reviewed annually and updated as needed to reflect changes in law, business operations, or industry standards.