Our obligations under the Modern Slavery Act 2018 (Cth) and (NSW), how we screen labour supply, and what happens when a supplier fails.
Owl Watch Services commits to upholding ethical standards and ensuring modern slavery has no place in our operations or supply chains. We recognise a legal and moral responsibility to combat all forms of modern slavery under the Modern Slavery Act 2018 (Cth) and the Modern Slavery Act 2018 (NSW). The security industry is particularly exposed through subcontracting and labour supply chains, which is why we identify and mitigate that risk proactively rather than in response to an audit.
This policy applies to employees, officers, contractors, suppliers, business partners and third parties acting on behalf of Owl Watch Services, across recruitment, procurement, service delivery and supply chain management.
We commit to treating all workers with dignity, implementing strict hiring practices, conducting risk assessments, engaging ethical partners, establishing reporting procedures, providing training, and taking decisive action against breaches including contract termination and reporting to the relevant authorities.
Modern slavery encompasses forced labour (work performed under threat and without consent), human trafficking (recruitment through coercion for the purpose of exploitation), debt bondage (forced work to repay unfair debts), servitude (an inability to leave due to coercion), child labour (employment that deprives children of education), and deceptive recruitment (misleading a worker about the conditions of work).
Internal operations. We conduct background checks, ensure wages comply with Australian law, and maintain transparent employment contracts that set out worker rights.
Supply chain management. All suppliers must adhere to our ethical sourcing requirements. We conduct risk assessments prioritising high-risk industries and regions, review supplier contracts for anti-slavery clauses, and undertake audits with corrective action plans.
Third-party labour providers. We engage only licensed labour hire companies compliant with Australian law. Labour firms must provide evidence of ethical recruitment and fair wages, and we conduct spot checks for indicators of exploitation.
Employees and stakeholders can report concerns through internal channels, a confidential whistleblower channel, or external authorities such as the Australian Border Force. All reports are taken seriously and investigated promptly.
Training is directed at employees working in recruitment and procurement, at security personnel who need to recognise indicators of forced labour, and at suppliers who need to understand what compliance with this policy requires.
Senior management enforces compliance with this policy. Annual reviews assess modern slavery risks, due diligence practices and supplier relationships, with policy updates reflecting legislative change and emerging risks.
We maintain zero tolerance. Breaches result in immediate termination of employment or the business relationship, reporting to authorities, and any applicable civil or criminal penalties.
Ethical sourcing. Suppliers must comply with Australian labour laws, Fair Work standards and international human rights conventions. We conduct regular audits, reject forced and child labour, and prioritise local and fair-trade sourcing.
Sustainability. We use energy-efficient systems, digital reporting to reduce paper waste, and source environmentally responsible products from sustainability-focused suppliers.
Business ethics and governance. Zero tolerance for corruption, fair employment practices, diversity and inclusion, legal compliance, and stakeholder engagement in ethical decision-making.
Annual reviews keep this policy aligned with evolving practice and legal requirements. We continue to enhance training, assess environmental impact, and strengthen partnerships with ethical organisations.
This policy is approved by senior management and endorsed by Director Hasnain Jafri.
