Ethical Purchasing Policy

1. Purpose

Anglicare is committed to eradicating modern slavery and human trafficking and to:

• acting ethically and with integrity and transparency in all of its business dealings and relationships; and
• implementing processes to minimise the occurrence of modern slavery and human trafficking either within its own operations or in any of its supply chains.

2. Guiding Principles

2.1.1. Anglicare is working toward eradicating any modern slavery in its own operations and supply
chains and expects the same commitment from its staff and Suppliers.
2.1.2. Eradicating modern slavery requires constant vigilance given the issue can manifest itself in a
number of ways including poor working standards, and payment of under award wages.
2.1.3. Given the possible cross-cultural impact of this policy, Anglicare looks to change behaviours
gradually through co-operation and vigilance.

3. Changes from previous versions

First version of the Anglicare Ethical Purchasing Policy

4. Policy

4.1.1. Anglicare commits to eliminating slavery and human trafficking within its supply chains and
operations as soon as reasonably possible.
4.1.2. This policy will apply to all Anglicare staff, and Suppliers including their employees, agents,
volunteers, contractors, consultants and business partners.
4.1.3. Due to the hidden nature of modern slavery, the process of identifying and eradicating it from it
from Anglicare supply chains and operations will develop incrementally and higher costs may
result from implementation.
4.1.4. Suppliers tendering for Anglicare contracts will be requested to certify to Anglicare their
compliance to the Anglicare Code of Practice, which requires them to:

• implement a policy within their workplace committing to 12 anti-slavery principles
• establish a process to monitor compliance with the anti-slavery principles;
• take action to remediate any breaches they are found to have committed.

4.1.5. In addition to the above, suppliers with total turnover of more than $100M per annum will also be
required to certify to Anglicare their compliance with the Commonwealth Modern Slavery Act
2018 (“the Act”).
4.1.6. Anglicare may at its discretion give preference in future works and orders to Suppliers who can
demonstrate compliance with this policy.

5. Procedures

5.1.1. Responsibility of Anglicare:

• Oversee implementation, compliance with and reporting on this Policy.

5.1.2. Responsibility of Suppliers:

• When tendering for Anglicare contracts, suppliers are required to certify that they
  comply or are implementing processes so as to comply with Anglicare Code of Practice

5.1.3. Responsibility of Anglicare Procurement:

• Identify key risk areas within Anglicare’ supply chains where non-compliance is more
  likely and take measures to ensure compliance.
• Monitor supplier compliance with the Anglicare Code of Practice and the Modern Slavery
  Act 2018.
• Create awareness on Modern Slavery risk across staff who carry out purchasing.
• In consultation with the Legal Support Officer, monitor developments in the laws
  concerning modern slavery.

5.1.4. Responsibility of Anglicare staff:

• Familiarise himself/herself with this policy

6. Bases of Discretion

Anglicare may at its discretion choose to not contract with suppliers who cannot satisfy its policy
requirements.

7. Explanatary Notes An Definitions

• Modern Slavery includes any practice constituting a modern slavery offence. The Act
  defines modern slavery as including eight types of serious exploitation: Trafficking in
  person, slavery, servitude, forced marriage, forced labour, debt bondage, the worst
  forms of child labour, and deceptive recruiting for labour or services.
• Supplier means a party including their employees, agents, volunteers, contractors,
  consultants and business partners that supplies goods or services to Anglicare in
  accordance with a written agreement between the two.

8. Supporting Documents

• Anglicare Procurement Policy
• The Commonwealth Modern Slavery Act 2018

9. Appendices

Appendix A: Anglicare Code of Practice (applicable to suppliers tendering for Anglicare contract
work or currently supplying to Anglicare)

Appendix B: Supplier self-certification as to compliance with the Modern Slavery Act 2018.
(applicable to Suppliers with an annual turnover of more than $100M pa).

10. Classification 

• Policy number – ANG010120
• Version – 1.0
• Last modified – 01/01/2020

This policy supersedes all previous policies relating to matters contained therein. In so much as any aspect of this policy may appear to be in conflict with another Anglicare or Departmental policy, then precedence is to be given to this policy.