Overview

The Modern Slavery Policy at Northeast Auto Group underpins our firm commitment to eradicating modern slavery in all forms. This policy reflects our dedication to conducting business ethically, transparently, and with respect for human rights. It establishes a comprehensive framework to prevent, detect, and address modern slavery within our operations and supply chains. By promoting due diligence, transparency, and collaboration, we strive to eliminate any association with modern slavery and contribute to the global fight against this heinous crime. This overview highlights our unwavering stance against modern slavery and our commitment to upholding human rights across our organization.

SCOPE

This policy applies to all employees, officers, directors, contractors, and stakeholders associated with Northeast Auto Group. It encompasses a comprehensive framework for preventing, detecting, and addressing modern slavery within our operations and supply chains. The scope includes rigorous due diligence, transparent reporting, and collaborative efforts to eliminate any form of modern slavery. By defining the scope, responsibilities, and measures, this policy reinforces our commitment to eradicating modern slavery and upholding human rights across our entire organizational ecosystem.

PURPOSE

This policy confirms our commitment to uphold the human rights of workers, and to treat them with dignity and respect. This applies to all full-time, part-time, casual, and contracted workers. We are further committed to paying employees and providing conditions of employment in accordance with an applicable and lawful industrial instrument approved by the Fair Work Commission and to the standards set in the Fair Work Act 2009.Northeast Auto Group confirms its commitment to contributing to ending all forms of modern slavery and outlines our approach to reducing the risk of modern slavery practices within our supply chains and operations.

OBJECTIVE

The objectives of our Modern Slavery Policy are to:
Prevent Modern Slavery: Establish robust measures to prevent instances of modern slavery within our organization fostering a culture that upholds human rights and ethical conduct.
Detect and Address: Implement mechanisms for the early detection of potential modern slavery risks, followed by thorough and impartial investigations to address any reported concerns.
Ensure Transparency: Promote transparency in our operations and supply chains by disclosing efforts to combat modern slavery and regularly reporting on progress and challenges.
By achieving these objectives, our policy aims to contribute to the eradication of modern slavery, uphold human rights, and foster a global business environment free from this egregious crime.

DEFINITIONS

Supply Chain: A supply chain is defined as a sequence of activities or parties that provides products or services to the organization.
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 labor in an unrestricted way

Policy

As part of the Northeast Auto Group recruitment and selection process, all employees contracted to work with our group must be engaged locally where available, be entitled by law to work in Australia and hold any current and relevant licenses, qualifications, certificates, visas, or authorization to conduct the work for which they have been engaged.
All employees must voluntarily choose to work with our group and shall be free to leave their employment at any time by terminating their employment in accordance with the relevant employment legislation, regulations or workplace laws governing the employee’s engagement.
Northeast Auto Group and/or any of its suppliers may not hold or otherwise destroy, conceal, confiscate, or deny access by employees to their identity or immigration documents, such as government-issued identification, passports, or work permits, unless such holdings are required by law.
Employees shall not be required to pay employers’ or agents’ recruitment fees or other related fees for their employment. If any such fees are found to have been paid by workers, such fees shall be repaid to the worker. Child or student labor is not to be engaged by the company or its suppliers.
In conformance with local law, participants shall respect the right of all workers to form and join trade unions of their own choosing, to bargain collectively and to engage in peaceful assembly as well as respect the right of workers to refrain from such activities. Additionally, workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices, both without fear of discrimination, reprisal, intimidation, or harassment.
Reporting unethical or unlawful conduct
A key to supporting ethical standards is enabling Northeast Auto Group and its subcontractors to feel free and safe to speak up when there are reasonable grounds to suspect that any person associated with Northeast Auto Group are not acting ethically or in accordance with laws and obligations.

Concerns about compliance or ethical issues or illegal or unethical activities are to be reported to Northeast Auto Group General manager Michelle Papalia at michelle.papalia@northeastauto.com.au.

Actions
Northeast Auto Group will take to eradicate Modern Slavery within its Supply Chains
Northeast Auto Group is committed to making sure that it does not engage suppliers that breach Modern Slavery legislation by regularly reviewing supply agreements.
Northeast Auto Group is committed to holding its suppliers accountable for their commitment of eradicating Modern Slavery and will not knowingly engage suppliers that do not align with its position on enforcing basic human rights.
Northeast Auto Group supply contracts will include a clause pertaining to Modern Slavery requiring the Supplier to:
• Provide commitments to eradicating Modern Slavery within its own supply chains.
• Warranting that it has not been convicted of a Modern Slavery offence; and
• Have completed its own due diligence on its supply chain.
Northeast Auto Group will conduct risk assessments to determine which areas of its supply chain are most at risk of Modern Slavery offences and implement risk minimization strategies.