HCS Modern Slavery Policy

Heavy Construction Solutions Pty Limited (“HCS”, “we”, “us” or “our”) is committed to acting ethically, with integrity and transparency in all business dealings, and to putting effective systems and controls in place to safeguard against any form of modern slavery within the business and its supply chains.

This policy sets out HCS’s commitment to identifying, preventing and addressing the risks of modern slavery and human trafficking in its operations and supply chains, consistent with the principles and expectations of the Modern Slavery Act 2018 (Cth) (the Act).

Although HCS falls below the A$100 million consolidated annual revenue threshold at which reporting is mandatory under the Act, HCS recognises that as a contractor and supplier to large reporting entities — including major telecommunications carriers, defence, mining and infrastructure clients — it is expected to demonstrate equivalent standards of due diligence so those clients can meet their own obligations.

1. SCOPE

This policy applies to all persons working for or on behalf of HCS in any capacity, including directors, officers and employees; apprentices, trainees, labour-hire workers and work-experience placements; contractors, subcontractors, consultants and agency workers; suppliers of goods and services and their downstream supply chains; and joint-venture partners and other business partners.

It covers all HCS operations across its Melbourne, Newcastle and Brisbane locations and any project site at which HCS personnel are engaged.

2. WHAT IS MODERN SLAVERY

“Modern slavery” describes situations where coercion, threats or deception are used to exploit victims and undermine their freedom. Under the Act it includes eight types of serious exploitation: trafficking in persons, slavery, servitude, forced labour, forced marriage, debt bondage, deceptive recruiting for labour or services, and the worst forms of child labour.

Modern slavery distorts global markets, undercuts responsible business and can cause severe and life-threatening harm to victims. HCS treats any indicator of modern slavery as a serious matter requiring immediate action.

3. OUR COMMITMENT

HCS has a zero-tolerance approach to modern slavery. We are committed to:

• Conducting our business ethically and lawfully, and respecting the human rights and dignity of all workers in our operations and supply chains;
• Identifying and assessing modern slavery risks in our operations and supply chains on a risk-prioritised basis;
• Engaging only with suppliers and subcontractors who can demonstrate that they uphold standards consistent with this policy;
• Embedding modern slavery considerations into procurement, engagement and contracting processes;
• Providing workers with safe, fair and lawful working conditions, freely chosen employment, and freedom from any form of coerced or bonded labour;
• Providing accessible avenues to raise concerns without fear of reprisal;
• Remediating any actual modern slavery harm that HCS causes, contributes to, or is directly linked to; and
• Reviewing and continually improving the effectiveness of our approach.

4. RESPONSIBILITIES

• Board / Directors — hold overall accountability for HCS’s response to modern slavery, approve this policy, and ensure adequate resources are allocated;
• Modern Slavery Officer — owns day-to-day implementation, maintains the risk assessment and supplier register, coordinates training and investigates reported concerns;
• Managers / Supervisors — apply this policy in procurement, engagement and site activities, and escalate any indicators of modern slavery;
• All workers — comply with this policy, complete required training, and report any concern or suspicion promptly;
• Suppliers and Subcontractors — comply with the HCS Supplier Code of Conduct, respond to due-diligence requests, and cascade equivalent standards to their own suppliers.

5. REPORTING CONCERNS

Any worker or business partner who suspects modern slavery in connection with HCS — however indirect — must report it immediately to a Director. Reports may be made openly or confidentially by contacting solutions@heavycs.com.au or 1300 859 027.

Where there is an immediate risk to a person’s safety, contact emergency services on 000. Suspected modern slavery can also be reported to the Australian Federal Police on 131 237 (131 AFP).

HCS will not tolerate retaliation against any person who raises a genuine concern in good faith.

6. BREACH OF POLICY

Any worker who breaches this policy may face disciplinary action up to and including termination of employment. HCS may terminate its relationship with any supplier, subcontractor or business partner found to be involved in modern slavery or that refuses to address identified risks.

7. REVIEW

This policy will be reviewed at least annually, and earlier if there are material changes to the Modern Slavery Act 2018 (Cth), to HCS’s operations or supply chains, or following any reported incident.