Modern Slavery Statement
Date: 1st December 2023
Review Date: 12 months from execution date above
Business: TechMedia Digital Systems Pty Limited (TechMedia)
Changes to this statement:
This statement may be amended or withdrawn by TechMedia at its’ discretion.
INTRODUCTION
This statement has been developed in accordance with the Australian Modern Slavery Act 2018 (Cth) (The Act) and is issued on behalf of TechMedia Digital Systems Pty Limited (ACN 088 175 428) referred collectively as TechMedia. This statement outlines the steps taken by TechMedia to identify, assess and reduce the risk of modern slavery practices within its operations or its supply chains during the year ending 31 December 2023.
TechMedia is committed to conducting its business in a moral and ethical way and recognises the need to establish and maintain corporate governance policies and business practices which reflect and comply with relevant legal and regulatory framework. In support of this commitment TechMedia will continuously improve its approach to addressing modern slavery risks, including implementing, and enforcing effective systems and controls.
STRUCTURE AND OPERATIONS
Structure
TechMedia is a small to medium enterprise incorporated in Australia and has its registered office in Sydney, New South Wales. As of 31 December 2023, TechMedia employed approximately 34 employees globally.
Direct operations
TechMedia is an Australian company based in Sydney, just south of the International Airport, that focuses on digitising Australia’s most recognisable brands.
Supply chains
TechMedia largest categories of supplier spending globally relate to the following key categories:
1. goods and services (including digital LED/LCD screens) needed to construct, install, operate, and maintain digital out of home & Connected Signage markets.
2. services needed for the everyday operations, including recruitment, legal and tax, auditing, information technology, telecommunications, and cleaning; and
3. software licences.
The majority of TechMedia’s suppliers are in Australia however some products and services are sourced from international suppliers based in regions such as Europe, Americas, and the Asia Pacific.
RISKS OF MODERN SLAVERY PRACTICES
Direct operations
Given the industry in which TechMedia operates and the locations of offices in low-risk jurisdictions (Australia) TechMedia has assessed the risk of modern slavery practices within TechMedia’s direct business operations as low.
TechMedia has appropriate workplace management policies and practices, along with skilled managers, to ensure appropriate recruitment and management of employees, including compliance with minimum remuneration requirements.
Supply chains
TechMedia has reviewed the risk of modern slavery practices across its supply chains with close consideration of the Commonwealth Modern Slavery Act 2018 – Guidance for Reporting Entities document (Guidance Document).
However, as TechMedia business expands, we are mindful of the increased risks relating to modern slavery associated particularly in TechMedia’s extended supply chain and higher risk categories or locations.
The Guidance Document assisted TechMedia to identify the following procurement categories as having a higher risk of modern slavery:
1. electronic equipment purchased from Australian vendors with supply chains extending to high-risk geographies; and
2. products manufactured offshore from high-risk categories including personal protective equipment, stationary, promotional products.
ACTIONS TO ASSESS AND ADDRESS MODERN SLAVERY RISKS
TechMedia’s commitment to identifying and eradicating modern slavery in its operations and supply chains is reflected in several policies, processes and practices implemented across TechMedia as of 31 December 2020.
Goods and services suppliers
TechMedia generally obtains goods and services from suppliers known to be reputable, substantial commercial entities. TechMedia has often dealt with those suppliers over many years, which provides TechMedia with a high level of confidence in the quality of their operations.
TechMedia personnel
TechMedia has human resources, finance, legal, procurement and internal audit teams whose roles include ensuring compliance with laws and internal policies and processes across the businesses.
TechMedia Code of Conduct and other policies
TechMedia Code of Conduct (Code) applies to all TechMedia personnel, including employees, contractors, managers, and directors.
The Code outlines standards, practices, and behaviours necessary to maintain confidence in the integrity of TechMedia and makes clear the behaviours expected of all TechMedia personnel to strengthen the internal culture of the business. This includes behaving ethically and complying with the law.
TechMedia has other policies to help guide the behaviours of its personnel, including Diversity Policy. All policies are available on TechMedia intranet.
Whistle-blower Policy
All recruitment for TechMedia is conducted by personnel located in New South Wales, Australia. TechMedia is therefore able to ensure that the process is conducted in an ethical and transparent manner and employment contracts contain fair and just terms in relation to wages, working hours and other working conditions.
This recruitment oversight aids in curbing any direct instances of modern slavery practices within TechMedia’s operations.
All new employees are given a copy of relevant TechMedia’s policies as part of their induction. TechMedia requires all new employees to acknowledge they have received and agree to abide by the relevant TechMedia policies.
ISO certification
TechMedia maintains a Workplace Health and Safety Management System. Its operations are not currently ISO certified.
Material agreement sign off
TechMedia requires any material agreement to be signed off from senior management of TechMedia. This approval includes consideration of risks relating to entering into an agreement with a supplier, which could include the identity, location, or operations of the counterparty.
ASSESSMENT OF EFFECTIVENESS
TechMedia understands that modern slavery risk is continually evolving and will remain vigilant to slavery and human trafficking in its supply chains. As part of TechMedia’s commitment to identify and eradicate modern slavery practices in its operations and supply chains the following additional actions have either commenced or are planned and will be reported on in subsequent statements.
Assurance questionnaires
Assurance questionnaires have been developed based on the supplier risk profile categorisation. The questionnaires will be given to new suppliers to complete and will assist TechMedia to identify and assess the risk of modern slavery practices occurring in its supply chains.
New supplier categorisation matrix
A new supplier categorisation matrix is used to extend TechMedia’s risk profiling by categorising a supplier’s risk levels based on territory, product type or service.
Modern slavery clauses in contracts
TechMedia is preparing to undertake an audit of its current supplier agreements and to include in any new agreement with suppliers (where possible) representations and obligations in relation to the supplier’s commitment to preventing modern slavery practices, the ability of the supplier to comply with the Acts and to cooperate with TechMedia by providing information required to assess modern slavery risks in their operations and supply chains.
Modern Slavery Policy
A Modern Slavery Policy will be implemented across TechMedia. The policy will solidify TechMedia’s commitment to identifying and addressing risks of modern slavery occurring in its supply chains and set out the standards of behaviour expected of TechMedia personnel in identifying and addressing modern slavery risks.
Code of conduct and other policies
TechMedia will amend its employee Code of Conduct & Anti-Bribery and Corruption Policy to ensure that staff practice ethical business standards and take steps such as conducting due diligence checks with respect to prospective suppliers and report any unlawful practices such as forced labour or slavery/slavery like practices observed in TechMedia’s supply chains.
Employee training
TechMedia intends to enhance training and awareness specific to modern slavery to all staff specifically involved in managing the supply chain. Once implemented, TechMedia will include its Modern-Day Slavery Policy in its suite of policies provided as part of new employee induction and ongoing employee training.
CONSULTATION
TechMedia has the required knowledge of the group’s operations to prepare this statement. Staff involved in the preparation of this statement have consulted with the necessary business operations of TechMedia to gather the necessary information to prepare this statement on behalf of TechMedia.