Therma Vision Pty Ltd
Modern Slavery Policy
1. Introduction and Purpose
Policy Statement
This Modern Slavery Policy (the "Policy") outlines Therma Vision Pty Ltd’s ("Therma Vision," "the Company") unequivocal commitment to preventing and addressing all forms of modern slavery within its operations and supply chains. Therma Vision acknowledges its responsibility to respect human rights and is dedicated to acting ethically and with integrity in all its business dealings and relationships. This commitment is not merely a response to legislative requirements but is a fundamental aspect of responsible corporate citizenship, particularly in light of the increasing global scrutiny on human rights violations and the substantial illicit profits generated by forced labour worldwide, estimated at $236 billion annually in a 2024 report.1
Objective
The primary objective of this Policy is to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in the Company's own business or in any of its supply chains. It provides a framework for identifying, assessing, mitigating, and reporting on modern slavery risks, and for remediating any adverse impacts. This proactive approach to managing and reporting on modern slavery risks also serves to protect Therma Vision from serious legal, reputational, operational, and financial risks associated with any connection to modern slavery.2 The development and implementation of this robust policy is also a response to observations that existing legislative frameworks, such as the Modern Slavery Act 2018 (Cth), have not yet driven sufficient meaningful change for those living in conditions of modern slavery.3 Consequently, this Policy emphasizes the adoption of tangible actions and the pursuit of measurable outcomes to ensure its genuine effectiveness.
Alignment with Values
This Policy aligns with Therma Vision’s core values of integrity, responsibility, and respect..
2. Scope
Applicability
This Policy applies to all persons working for or on behalf of Therma Vision in any capacity. This includes employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.
Geographical Reach
It applies to all operations of Therma Vision, whether domestic or international, and extends to all entities owned or controlled by Therma Vision. The inclusion of "entities owned or controlled" is a critical aspect of modern slavery legislation 2 and adopting this scope demonstrates best practice and preparedness for any potential future mandatory reporting obligations.
Supply Chain Expectation
Therma Vision expects its suppliers, and their suppliers (sub-tier suppliers), to adhere to principles consistent with this Policy. The Modern Slavery Act 2018 (Cth) (the "Act") places significant emphasis on supply chain due diligence, requiring companies to assess their operations and scrutinize their suppliers and subcontractors.1 Therma Vision will work collaboratively with its supply chain partners to help them understand and meet these expectations. It is recognized that the ability to influence will vary across the supply chain; the approach to sub-tier suppliers will necessarily differ from direct (Tier 1) suppliers, focusing on encouraging Tier 1 suppliers to cascade these requirements and principles further down the chain.
3. Definitions
Modern Slavery
As defined by the Modern Slavery Act 2018 (Cth), modern slavery is an umbrella term describing situations where offenders use coercion, threats, or deception to exploit victims and undermine or deprive them of their freedom.5 It encompasses serious exploitation and includes the following practices 2:
Human Trafficking: The recruitment, transportation, transfer, harbouring or receipt of persons, by means of threat or use of force or other forms of coercion, abduction, fraud, deception, abuse of power or of a position of vulnerability, or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation.
Slavery: Situations where a person exercises powers of ownership over another person.
Servitude: Situations where a person’s personal freedom is significantly restricted, and they are not free to cease working or leave their place of work.
Forced Labour: Situations where a person is not free to cease working or to leave their place of work, often involving coercion, threats or deception.
Debt Bondage: Situations where a person is forced to work to pay off a debt, often with no real prospect of repayment, and the debt may be unfairly inflated or the services undervalued.
Forced Marriage: Where a person gets married without freely and fully consenting because they have been coerced, threatened or deceived, or because they are incapable of understanding the nature and effect of a marriage ceremony.
Worst Forms of Child Labour: Situations that are mentally, physically, socially or morally dangerous and harmful to children; and/or interfere with their schooling. This includes child trafficking, child slavery, and the use of children in armed conflict, pornography, or illicit activities.
Deceptive recruiting for labour or services.
It is important to distinguish modern slavery from other harmful practices such as substandard working conditions or underpayment of workers. While these practices are also unacceptable and may be illegal, they are not included in the definition of modern slavery unless elements of coercion, threat, or deception to exploit and undermine freedom are present.5 However, the presence of such substandard conditions can be an indicator of, or escalate into, modern slavery if not addressed. Therefore, Therma Vision’s risk assessment processes will remain sensitive to these precursor issues.
Operations
Refers to all business activities undertaken by Therma Vision, including but not limited to research, design, manufacturing, service delivery, internal administration, and employment practices. The Attorney-General's Department (AGD) is expected to provide ongoing clarification on the precise scope of 'operations' 3, and this Policy will adapt to such guidance.
Supply Chains
Encompasses all entities and individuals involved in providing goods and services to Therma Vision, from raw material extraction and component manufacturing to the delivery of the final product or service. This includes direct (Tier 1) suppliers and indirect (sub-tier) suppliers. As with 'operations', the AGD is anticipated to provide further guidance on this term.3
Reporting Entity
An entity based or operating in Australia with an annual consolidated revenue of at least AU$100 million, as per the Modern Slavery Act 2018 (Cth).1 The term 'entity' is not limited to corporations and can include structures such as trusts.4 This broad definition is pertinent for Therma Vision if its structure involves, or it controls, such diverse entities, as this would impact the scope of due diligence and potential reporting obligations.
4. Our Commitment to Eradicating Modern Slavery
Formal Statement
Therma Vision Pty Ltd is unequivocally committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its operations and supply chains are free from slavery and human trafficking. The Company adopts a zero-tolerance approach to modern slavery. This strong stance is operationalized through robust risk management processes, due diligence, and a commitment to continuous improvement, rather than a mere assertion of being "slavery free," recognizing that the Act requires entities to demonstrate concrete steps towards understanding and managing their risks.2
Ethical Standards
Therma Vision is committed to acting ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its own business or its supply chains. This commitment extends beyond mere compliance to actively contributing to the eradication of modern slavery, aligning with the spirit of the United Nations Guiding Principles on Business and Human Rights (UNGPs).5
Continuous Improvement
Therma Vision is committed to continuously improving its practices to identify and eliminate modern slavery risks. This includes regularly reviewing the effectiveness of its policies, procedures, and due diligence processes, in line with the expectation for reporting entities to adopt a "continuous improvement" approach.11
5. Legal and Regulatory Context
Primary Legislation
This Policy is developed in accordance with the Modern Slavery Act 2018 (Cth) (the "Act"). The Act requires entities based, or operating, in Australia, which have an annual consolidated revenue of AU$100 million or more, to report annually on the risks of modern slavery in their operations and supply chains, and actions to address those risks.1
Reporting Requirements
If Therma Vision meets the revenue threshold, it must submit an annual Modern Slavery Statement to the Australian Government. This statement must address mandatory criteria outlined in the Act and is made publicly available on the Modern Slavery Statements Register.5
NSW Legislation
Therma Vision acknowledges the Modern Slavery Act 2018 (NSW), particularly if operating in New South Wales. This includes its interaction with the Commonwealth Act, such as the voluntary reporting by NSW State-owned entities under the Federal Act and the establishment of the NSW Anti-Slavery Commissioner.4
International Standards
Therma Vision acknowledges and respects internationally recognized human rights standards, including the United Nations Guiding Principles on Business and Human Rights (UNGPs), the Universal Declaration of Human Rights, and the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work.2
Anticipated Developments
Therma Vision will monitor and adapt to legislative reforms, including those arising from the statutory review of the Act (report tabled in Parliament May 2023, government response December 2024). This includes potential changes to reporting criteria, the introduction of mandatory due diligence requirements, and the introduction of penalties for non-compliance.1
The Australian Government's "agreed in principle" stance on introducing civil penalties for non-compliance with the Act 3 signals a significant shift. This moves beyond the current enforcement model, which largely relies on reputational risk, towards a regime with direct legal and financial repercussions. This development makes robust policy implementation and diligent adherence even more critical for Therma Vision.
Furthermore, the establishment of the Australian Anti-Slavery Commissioner in 2024 6 introduces a new dynamic. The Commissioner is tasked with promoting compliance, supporting businesses in addressing risks, raising community awareness, and potentially declaring high-risk regions, products, or suppliers.3 This creates both a valuable resource for guidance and a new layer of oversight for businesses.
While the mandatory reporting threshold currently remains at AU$100 million in annual consolidated revenue, the government has "noted" the recommendation from the statutory review to lower this to AU$50 million and will reconsider this in the future.3 Entities with revenues between AU$50 million and AU$100 million should therefore not be complacent. Proactive alignment with the Act's requirements is advisable as a matter of good governance and to ensure preparedness for potential future mandatory reporting obligations.
6. Governance, Roles, and Responsibilities
Overall Accountability
The Board of Directors (or equivalent principal governing body) of Therma Vision has ultimate responsibility for ensuring this Policy and Therma Vision’s Modern Slavery Statement (if applicable) comply with the Company’s legal and ethical obligations. The Board will approve this Policy and any subsequent Modern Slavery Statements, as required for reporting entities.13 The visible commitment and championing of this issue by the Board and Senior Management are critical in setting the "tone from the top," which significantly influences company culture and the seriousness with which this Policy is regarded throughout the organization.
Senior Management Endorsement
Senior Management is responsible for the day-to-day implementation of this Policy, ensuring adequate resources are allocated, and fostering a company culture that prioritizes the eradication of modern slavery. Effective governance requires not only assigning roles but also ensuring that those in these roles have the necessary authority, resources, and training to fulfill their responsibilities.
Designated Lead
will have operational responsibility for coordinating activities under this Policy. This includes leading risk assessments, overseeing due diligence processes, coordinating training programs, and preparing reports.
Specific Departmental Responsibilities
The responsibility for implementing this Policy is shared across various functions within Therma Vision. The following table outlines key responsibilities:
Table 1: Key Modern Slavery Responsibilities
Role/Department
Board of Directors / Principal Governing Body
Senior Management
Procurement & Supply Chain Teams
Human Resources
Legal/Compliance
All Employees & Contractors
Key Responsibilities
Overall oversight of modern slavery risk management; Approval of this Policy and annual Modern Slavery Statement (if applicable); Championing a culture of ethical conduct; Ensuring the policy is effectively implemented.
Driving implementation of this Policy; Allocating necessary resources; Ensuring integration of modern slavery considerations into business strategy and operations; Receiving regular updates on modern slavery risks and compliance.
Conducting supplier risk assessments and due diligence (including for sub-contractors where feasible and appropriate 1); Implementing supplier codes of conduct and contractual clauses regarding modern slavery; Engaging with suppliers on modern slavery issues and improvement plans; Monitoring supplier compliance; Training relevant staff on supply chain risks.
Developing and delivering modern slavery training to employees 2; Managing grievance mechanisms for direct employees; Ensuring ethical recruitment and employment practices within Therma Vision’s own operations to prevent any form of forced labour or exploitation.
Advising on legal obligations under the Modern Slavery Act 2018 (Cth) and other relevant laws; Monitoring legislative changes and guidance from the Anti-Slavery Commissioner; Supporting policy review and updates; Overseeing or supporting investigations into reported concerns.
Understanding and adhering to this Policy; Completing required training on modern slavery awareness and identification; Reporting any suspected instances of modern slavery through designated channels without fear of reprisal.
7. Identifying and Assessing Modern Slavery Risks
Risk Assessment Framework
Therma Vision will implement and maintain a systematic process to identify, analyze, and evaluate modern slavery risks within its operations and supply chains. This will be an ongoing process, subject to review at least annually, and additionally in response to significant changes in operations, supply chains, or the external environment. Such changes include, but are not limited to, new high-risk declarations that may be issued by the Australian Anti-Slavery Commissioner 3, which could significantly shift risk priorities. This dynamic approach ensures the risk assessment remains relevant and responsive.
Risk Factors in Operations
The assessment of risks within Therma Vision’s direct control will consider:
Employment practices, including direct hires, the use of labour-hire agencies, and the employment of migrant workers.
Working conditions and compliance with wage and hour laws.
The presence of vulnerable worker groups within the workforce.
Risk Factors in Supply Chains
The assessment of risks associated with suppliers will consider a range of factors, including:
Geographic Risk: Sourcing from or operating in countries with a known higher prevalence of modern slavery, informed by resources such as the Global Slavery Index 6 and future declarations by the Anti-Slavery Commissioner.
Sector/Industry Risk: Involvement with industries known to have higher inherent risks of modern slavery, such as agriculture, construction, electronics manufacturing, garment production, and cleaning services.18
Product/Service Risk: Procurement of specific goods or services that involve high-risk inputs or production processes.
Supplier-Specific Risk: Characteristics of individual suppliers, such as poor track records on labour standards, opaque ownership structures, reliance on high-risk recruitment practices (e.g., recruitment fees charged to workers), or a lack of their own policies addressing modern slavery.18
Entity Risk: Characteristics of supplier entities themselves, such as poor governance structures or a documented history of human rights violations.11
Tools and Methodologies
Therma Vision will utilize a variety of tools and methodologies for risk assessment. These may include developing and deploying supplier self-assessment questionnaires, conducting internal audits of procurement practices, undertaking site visits to supplier facilities (where feasible, appropriate, and proportionate to the risk), and gathering information from credible external sources. Such sources include reports from non-governmental organizations (NGOs), academic research, industry-specific reports, and government advisories, such as the Inherent Risk Identification Tool developed by the NSW Anti-slavery Commissioner's office.19 The risk assessment process will be integrated into ongoing procurement and supplier management activities, including initial supplier onboarding and regular performance reviews 16, rather than being a standalone annual exercise. This operational integration is key to preventing new risks from entering the supply chain and managing existing ones effectively.
Furthermore, while this Policy focuses specifically on modern slavery as defined by the Act, the risk assessment process will remain aware that broader Environmental, Social, and Governance (ESG) risks can be interlinked. For instance, poor environmental practices or corruption within a supplier's operations might correlate with exploitative labour conditions.9 Acknowledging these potential interconnections can yield more comprehensive risk insights.
8. Due Diligence Processes
Principles
Therma Vision’s due diligence processes will be proportionate to the identified level of modern slavery risk, the Company's leverage over the relevant entity or supplier, and the severity of potential modern slavery impacts. This approach is consistent with the UNGPs.2 The Australian Government is currently consulting on proposals to amend the Act to enhance due diligence requirements.3 While a specific mandate for entities to have a prescribed due diligence system was "noted" rather than immediately adopted from the statutory review recommendations 3, the clear direction of regulatory development, both in Australia and globally, is towards more explicit human rights due diligence obligations. Therma Vision will therefore proactively build and refine robust due diligence systems in anticipation of these evolving expectations.
Supplier Pre-Qualification
Modern slavery risk considerations will be integrated into supplier selection and onboarding processes. This may involve:
Requiring potential suppliers to complete self-assessment questionnaires focusing on their labour practices, existing policies related to human rights, and risk management procedures.11
Requesting copies of suppliers' own Modern Slavery Policies or Statements, where available.12
Contractual Clauses
Therma Vision will incorporate clauses in new and renewed supplier contracts that require adherence to the Therma Vision Supplier Code of Conduct (which will include explicit prohibitions against all forms of modern slavery). These clauses will also mandate compliance with all applicable modern slavery laws and affirm Therma Vision’s right to verify compliance. Verification methods may include conducting audits (with reasonable notice) or requesting specific information related to labour practices and supply chain management.7
Ongoing Monitoring
Regular monitoring of key suppliers, particularly those identified as carrying a high modern slavery risk, will be undertaken. This monitoring may involve:
Periodic re-assessments or updated questionnaires.
Desktop reviews of publicly available information or supplier-provided documentation.
Where appropriate, feasible, and proportionate to the risk, on-site audits, which may be conducted by Therma Vision personnel or qualified third-party auditors.12
Structured engagement with suppliers to discuss their progress in identifying and addressing modern slavery risks within their own operations and supply chains.
Enhanced Due Diligence
For suppliers, specific product lines, or geographic regions identified as carrying a particularly high modern slavery risk, Therma Vision will undertake enhanced due diligence. This may include more in-depth investigations into specific concerns, direct engagement with workers or their legitimate representatives (where this can be done safely and ethically), collaboration with independent auditors specializing in social compliance, or consultation with civil society organizations with relevant expertise.
Addressing Non-Compliance
If a supplier is found to be involved in modern slavery practices, or fails to take adequate steps to address identified risks despite engagement, Therma Vision will work collaboratively with the supplier to implement a time-bound corrective action plan. The Company's primary aim will be to drive improvement and remediate harm. If a supplier is unwilling or unable to address the issues satisfactorily and demonstrably improve its practices, Therma Vision will review the business relationship. This review may lead to consequences up to and including the suspension of new orders or the termination of the contract, particularly in cases of material breach where the supplier demonstrates no genuine intention to remedy the situation.16 The potential for future penalties for failing to comply with a request from authorities for specified remedial action further underscores the importance of effective internal processes for addressing non-compliance.3
Effective due diligence involves not only identifying risks but also strategically using leverage to drive improvement. Where Therma Vision has significant commercial leverage with a supplier, it has a correspondingly greater capacity, and responsibility, to influence positive change. Conversely, where leverage is limited (e.g., with very large, powerful suppliers or those deep in the supply chain), collaborative approaches with other buyers or industry initiatives may prove more effective. For small and medium-sized enterprises (SMEs) within Therma Vision's supply chain, a supportive and capacity-building approach will be prioritized over simply imposing requirements, recognizing that collaboration can be more effective than a purely punitive stance.11
9. Actions to Address and Mitigate Risks
Supplier Engagement
Therma Vision will proactively engage with its suppliers to clearly communicate its expectations regarding the prevention of modern slavery. This will primarily be achieved through the dissemination and integration of the Therma Vision Supplier Code of Conduct.12 Suppliers will be encouraged to adopt similar standards and expectations within their own supply chains, creating a cascading effect of responsible practices.2
Capacity Building
Where appropriate and feasible, especially for suppliers identified as high-risk but demonstrating a willingness to improve, Therma Vision will seek to support their capacity to identify and manage modern slavery risks. This support could take various forms, such as sharing best practice examples, providing access to relevant training materials or resources, or collaboratively developing improvement plans.17
Corrective Action Plans (CAPs)
When modern slavery risks or actual incidents are identified, either within Therma Vision’s operations or its supply chains, time-bound CAPs will be developed and implemented. These plans will be formulated in collaboration with the relevant supplier or internal department and will clearly define the steps to be taken, responsibilities, and timelines for addressing the identified issues. Therma Vision will monitor the implementation and effectiveness of these CAPs.
Collaboration
Therma Vision recognizes that modern slavery is a complex, systemic issue that often cannot be tackled effectively by one organization alone. Therefore, the Company will seek opportunities to collaborate with industry peers, government bodies (including the Anti-Slavery Commissioner's office), civil society organizations, and multi-stakeholder initiatives. Such collaborations can facilitate the sharing of information, the development of sector-wide best practices, and collective action to address systemic modern slavery risks.17 The Australian Competition and Consumer Commission (ACCC) has provided guidance indicating that pre-competitive collaboration on sustainability issues, including initiatives to combat modern slavery (such as joint supplier audits or sharing information on high-risk suppliers), is permissible and encouraged.15 This provides a framework for lawful collaboration that can be particularly useful for SMEs or when dealing with shared suppliers where individual leverage is limited.
Responsible Disengagement
If a supplier is found to be involved in severe modern slavery practices and is unable or unwilling to remediate these practices despite sustained engagement and support, Therma Vision will consider responsible disengagement from the relationship. This decision will not be taken lightly and will involve careful consideration of the potential adverse impacts on the affected workers. Where possible, Therma Vision will seek to mitigate these impacts, for example, by providing reasonable notice, encouraging the supplier to fulfill outstanding obligations to workers, or coordinating with other buyers or stakeholders. Simply severing ties without regard for the consequences for workers can often leave them in an even more vulnerable situation.2
10. Training and Awareness
Targeted Training
Therma Vision will provide regular and targeted training on modern slavery risks and the requirements of this Policy to relevant personnel. This includes:
Board members and senior management, focusing on governance responsibilities, strategic implications of modern slavery risks, and their role in championing this Policy.
Procurement, sourcing, and supply chain management teams, focusing on supplier risk assessment methodologies, due diligence techniques, effective supplier engagement on modern slavery issues, identifying red flags of exploitation 18, and managing non-compliance.
Human Resources staff, focusing on ethical recruitment practices, ensuring fair treatment of directly employed and contract staff, managing internal grievance mechanisms effectively, and understanding worker rights.
Employees who have direct and regular contact with suppliers or who operate in potentially high-risk environments.
General Awareness
Broader awareness of modern slavery issues, the core principles of this Policy, and how to report concerns will be raised among all employees and, where appropriate, contractors.2
Content
Training programs will cover, at a minimum:
Clear definitions of modern slavery and its various forms (e.g., forced labour, debt bondage, human trafficking).
How to identify potential red flags or indicators of modern slavery in operational and supply chain contexts.18
An overview of Therma Vision’s policies, procedures, and commitments related to combating modern slavery.
Specific roles and responsibilities of different employee groups in implementing this Policy.
The available channels for reporting suspected instances of modern slavery and the protections afforded to whistleblowers.
Record Keeping
Therma Vision will maintain records of all modern slavery training provided, including dates, attendees, and content covered. The effectiveness of training programs will also be periodically assessed, moving beyond simple completion metrics to evaluate understanding and practical application of the training content. Extending awareness training or resources to key suppliers, or encouraging suppliers to conduct their own training for their staff and potentially their own key suppliers 19, will be considered as a means to significantly amplify the impact of Therma Vision's efforts, particularly within complex supply chains.
11. Grievance and Remediation Mechanisms
Accessible Channels
Therma Vision will establish and maintain clear, confidential, and accessible grievance mechanisms. These channels will be available for Therma Vision employees, workers in its supply chains (where feasible and appropriate), and other external stakeholders to report concerns or suspected instances of modern slavery without fear of retaliation or detriment.
Mechanisms may include a dedicated, independently managed hotline, a secure online reporting portal, or clearly designated and trained contacts within the company.
Information about these grievance mechanisms, including how to access them, will be communicated effectively. This includes ensuring information is available in relevant languages and accessible formats, particularly for workers in diverse supply chains. Making such mechanisms genuinely accessible to workers deep within supply chains presents significant challenges, but Therma Vision will explore collaborative approaches with suppliers or third-party providers to enhance reach.
Investigation Process
A clear, consistent, and impartial process will be defined for promptly investigating all reported concerns or allegations of modern slavery. Investigations will be conducted by appropriately trained personnel, ensuring confidentiality for the reporter (where requested and permissible by law) and robust protection for whistleblowers against any form of reprisal.
Remediation Framework
Where modern slavery practices are identified and substantiated, Therma Vision is committed to providing or cooperating in the remediation of adverse impacts on victims. The approach to remediation will be victim-centric, guided by principles outlined in the UNGPs 2, and will aim to restore victims, as far as possible, to the situation they would have been in had the abuse not occurred. Remediation is not solely about financial compensation; it is a holistic process aimed at ensuring justice for the victim and preventing recurrence. Specific remediation actions will vary depending on the circumstances but may include:
Facilitating the repayment of withheld wages or recruitment fees.
Ensuring safe and fair working conditions are restored.
Supporting access to necessary support services, which may include medical treatment, legal advice, or psychological counselling.
Addressing the root causes of the exploitation within the workplace or supply chain to prevent future occurrences.
Effectiveness Review
The effectiveness of Therma Vision’s grievance and remediation mechanisms will be regularly reviewed. This review will consider factors such as accessibility, awareness among potential users, usage rates, the timeliness and fairness of investigations, and the adequacy of outcomes for victims. The anticipated inclusion of "grievance and complaint mechanisms" as a mandatory reporting criterion under the Act 3 makes this a priority area. Furthermore, the government's consideration of penalties for "failing to comply with a request for specified remedial action" 3 indicates that remediation efforts may come under greater regulatory scrutiny, making a robust and well-documented internal framework crucial.
12. Monitoring and Assessing Effectiveness
Key Performance Indicators (KPIs)
Therma Vision will develop and track relevant Key Performance Indicators (KPIs) to measure the effectiveness of the actions taken to identify, assess, address, and remediate modern slavery risks. Measuring effectiveness in combating modern slavery is inherently challenging, as success often involves the absence of exploitation. Therefore, KPIs will encompass both process indicators (reflecting efforts and implementation) and, where possible, outcome indicators (reflecting actual impact). Examples may include:
Percentage of key suppliers (prioritized by risk) that have undergone modern slavery risk assessments and due diligence.
Number and roles of employees who have completed modern slavery training.
Number and nature of grievances received through reporting channels related to modern slavery, and the proportion that are investigated and resolved satisfactorily.
Evidence of tangible improvements in supplier labour practices following engagement or the implementation of corrective action plans.
Number of workers who have received remedy for modern slavery related harms.
Regular Reviews
Therma Vision will conduct regular internal reviews of the implementation and effectiveness of this Policy and its related procedures. These reviews will consider the latest risk assessment findings, outcomes from due diligence activities, the impact of training programs, data from grievance mechanisms, and feedback from internal and external stakeholders.
Management Reporting
Regular reports on modern slavery risks, actions taken, performance against KPIs, and the overall effectiveness of these actions will be provided to Senior Management and the Board of Directors. This reporting will inform strategic decision-making and resource allocation for continuous improvement. Assessing effectiveness is a mandatory reporting criterion for entities subject to the Act 4 and is essential for demonstrating that the policy is a living document leading to tangible change rather than a static compliance exercise. Feedback from stakeholders, including workers (obtained through safe and confidential channels), suppliers, and civil society organizations, can provide valuable external perspectives for assessing effectiveness, potentially uncovering insights that internal audits might miss.2
13. Reporting and Transparency
Mandatory Reporting (if applicable)
If Therma Vision meets the criteria of a reporting entity under the Modern Slavery Act 2018 (Cth) (i.e., consolidated revenue of AU$100 million or more 1), it will prepare and submit an annual Modern Slavery Statement. This Statement will be submitted to the responsible Minister via the Australian Government's online Modern Slavery Statements Register within six months of the end of Therma Vision’s financial year.4
Content of Statement
The Modern Slavery Statement will, at a minimum, address the seven mandatory criteria outlined in section 16 of the Act 4:
Identification of the reporting entity.
Description of the entity's structure, operations, and supply chains.
Description of the risks of modern slavery practices in the operations and supply chains of the reporting entity (and any entities it owns or controls).
Description of the actions taken by the reporting entity (and any entities it owns or controls) to assess and address these risks, including due diligence and remediation processes.
Description of how the reporting entity assesses the effectiveness of such actions.
Description of the process of consultation with any entities that the reporting entity owns or controls, or with which a joint statement is being prepared.
Provision of any other information that the reporting entity considers relevant.
The Australian Government is expected to consult on expanding these mandatory reporting criteria in the future, potentially to include specific details on modern slavery incidents identified, the functioning of grievance and complaint mechanisms, and internal and external consultation undertaken on risk management.3 Therma Vision will proactively monitor these developments and ensure its internal systems are capable of collecting such information.
Approval and Signature
The Modern Slavery Statement must be approved by Therma Vision’s principal governing body (e.g., the Board of Directors) and signed by a responsible member of that body (e.g., a Director) before submission.13
Voluntary Reporting
If Therma Vision does not currently meet the mandatory reporting threshold, it may still consider voluntarily preparing and submitting a Modern Slavery Statement.2 This can be a valuable way to demonstrate the Company's commitment to transparency and responsible business practices. Should Therma Vision choose to report voluntarily, it must address all the mandatory reporting criteria as if it were a reporting entity.11
Internal Reporting
Regular internal reports on modern slavery risks, compliance activities, and progress against this Policy will be provided to Senior Management and the Board of Directors.
Public Availability
Modern Slavery Statements submitted to the Australian Government are published on an online, publicly accessible register.5 This public transparency means that Therma Vision's actions (or inactions) are open to scrutiny by investors, customers, civil society organizations, and industry peers, creating a strong reputational incentive for robust and genuine compliance efforts. Therma Vision may also choose to publish its Modern Slavery Policy and/or its Modern Slavery Statement on its own corporate website. The quality of Modern Slavery Statements has been subject to scrutiny, with concerns raised about a "box-ticking" approach by some entities.21 Therma Vision will aim to produce high-quality, transparent, and candid statements that genuinely reflect its efforts, challenges, and progress.
14. Consultation
Internal Consultation
When preparing its Modern Slavery Statement (if applicable), Therma Vision will consult with any entities it owns or controls. This consultation is a mandatory reporting criterion 2 and is essential to ensure that the modern slavery risks and actions taken within these related entities are accurately and comprehensively reflected in the Statement. The Australian Government has acknowledged that there can be challenges associated with joint reporting for corporate groups and has committed to providing further guidance in this area.3 Therma Vision will monitor such guidance if it operates within a complex group structure or considers submitting a joint statement.
External Consultation (as appropriate)
Therma Vision may also consult with relevant external stakeholders to inform its risk assessments, due diligence processes, remediation approaches, and overall modern slavery strategy. Such stakeholders could include suppliers, industry bodies, non-governmental organizations (NGOs), trade unions, and academic experts.2 The government is also considering making "internal and external consultation undertaken" a mandatory reporting criterion in the future.3 Meaningful consultation, particularly with potentially affected stakeholders like workers or their legitimate representatives (conducted through safe and appropriate channels), can provide invaluable insights into actual risks on the ground and the true effectiveness of mitigation measures, going beyond simple information sharing.
15. Policy Review and Continuous Improvement
Regular Review
This Policy will be reviewed at least annually by the and subsequently approved by the Board of Directors. The review process will be documented, including the rationale for any changes made or decisions not to make changes, to support accountability and demonstrate a considered approach to continuous improvement. The review will take into account:
Changes in relevant legislation, regulations, and official guidance, including any new materials or directives issued by the Australian Anti-Slavery Commissioner.6
The outcomes of Therma Vision’s own risk assessments and due diligence activities.
An evaluation of the effectiveness of current processes, controls, and remediation efforts.
Feedback received from internal and external stakeholders.
Evolving international standards and industry best practices in combating modern slavery.
Commitment to Improvement
Therma Vision is committed to continuously improving its approach to identifying, assessing, and addressing modern slavery risks within its operations and supply chains.11 The appointment of the Australian Anti-Slavery Commissioner, who is mandated to support businesses and promote compliance 6, is expected to contribute to an evolving landscape of best practices and heightened expectations. The policy review process must actively seek to incorporate these developments to ensure the Policy remains robust and effective.
16. Consequences of Non-Compliance with this Policy
Internal Disciplinary Action
Any employee of Therma Vision found to be in breach of this Policy will face disciplinary action. Such action will be determined in accordance with Therma Vision’s established disciplinary procedures and applicable employment law, and could range from warnings to suspension or termination of employment for serious or repeated violations.
Supplier Non-Compliance
Therma Vision may suspend or terminate its relationship with other individuals and organizations working on its behalf, including suppliers and contractors, if they are found to be involved in modern slavery, breach this Policy, or fail to adequately address identified modern slavery risks despite engagement and opportunities for remediation.16 While disciplinary measures and contractual remedies are important, they are most effective when balanced with a strong organizational culture that encourages open reporting and protects whistleblowers, as outlined in the Grievance and Remediation Mechanisms section. Fear of reprisal can deter reporting, thereby hindering the early identification of potential issues.
It is also important to recognize that beyond internal or contractual consequences, the Australian Government is moving towards introducing direct penalties for non-compliance with the Modern Slavery Act 2018 (Cth) itself, such as for failing to submit a statement or providing false information.3 This adds a significant external layer of potential consequences, reinforcing the overall importance of robust compliance with both this Policy and statutory obligations.
17. Related Documents and Resources
The following documents and resources provide further information relevant to this Policy:
Modern Slavery Act 2018 (Cth)
Australian Government Attorney-General’s Department – Modern Slavery resources, including the "Commonwealth Modern Slavery Act – Guidance for Reporting Entities" 9
Resources from the Office of the Australian Anti-Slavery Commissioner (as they become available)
United Nations Guiding Principles on Business and Human Rights
This list will be reviewed and updated regularly as part of the policy review cycle to ensure it remains current and directs users to the most relevant information, particularly as new guidance and resources emerge from bodies such as the Anti-Slavery Commissioner's office.6
18. Conclusion and Key Actions for Therma Vision Pty Ltd
This Modern Slavery Policy establishes Therma Vision Pty Ltd’s firm commitment and comprehensive framework for preventing and addressing modern slavery within its sphere of influence. Adherence to this Policy is mandatory for all employees and is expected of all business partners.
The successful implementation of this Policy requires ongoing vigilance, proactive risk management, and a commitment to continuous improvement from all parts of the organization. Key actions for Therma Vision arising from this Policy include:
Embedding Governance: Ensuring the Board and Senior Management actively oversee and champion the commitments within this Policy, and that designated roles and responsibilities are clearly understood and resourced.
Robust Risk Assessment: Implementing and regularly updating a dynamic risk assessment process that identifies specific modern slavery risks in both operations and supply chains, responsive to evolving external factors like declarations from the Anti-Slavery Commissioner.
Effective Due Diligence: Integrating modern slavery considerations into all stages of supplier engagement, from pre-qualification to ongoing monitoring, with enhanced due diligence applied to high-risk areas.
Capacity Building and Training: Investing in targeted training for relevant employees and raising awareness across the organization to ensure a comprehensive understanding of modern slavery risks and reporting obligations.
Accessible Grievance Mechanisms: Maintaining and promoting effective, confidential grievance mechanisms that are accessible to employees and, where feasible, workers in the supply chain, coupled with a robust remediation framework.
Monitoring and Reporting: Continuously monitoring the effectiveness of actions taken, using relevant KPIs, and ensuring transparent reporting, whether mandatory or voluntary, that meets or exceeds legislative requirements and stakeholder expectations.
Adaptation and Improvement: Regularly reviewing this Policy and associated procedures to adapt to legislative changes, evolving best practices, and lessons learned from implementation.
By diligently implementing this Policy, Therma Vision Pty Ltd aims not only to comply with its legal obligations but also to contribute meaningfully to the global effort to eradicate modern slavery and uphold fundamental human rights.