Tommy Associates Pty Ltd
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Modern Slavery Policy

Last updated date: 13th January 2021
Modern Slavery is a crime and a violation of fundamental human rights. It takes various forms such as slavery, servitude, forced and compulsive labour and human trafficking.;


The purpose of this Policy is to outline Tommy Associates Pty Ltd group of companies (Tommy) requirements and expectations of its suppliers in regard to Modern Slavery. The Policy also sets out the actions undertaken by Tommy to reduce the risk of Modern Slavery in its supply chain.


Modern Slavery is a crime and a violation of fundamental human rights. It takes various forms such as slavery, servitude, forced and compulsive labour and human trafficking.
(a) an offence under Division 270 or 271 of the Criminal Code; or
(b) an offence under either of those Divisions if the conduct took place in Australia; or
(c) trafficking in persons, as defined in Article 3 of the Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children, supplementing the United Nations Convention against Transnational Organised Crime, done at New York on 15 November 2000 ([2005] ATS 27); or
(d) the worst forms of child labour, as defined in Article 3 of the ILO Convention (No. 182) concerning the Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labour, done at Geneva on 17 June 1999 ([2007] ATS 38).
Supplier means any individual, company or entity that sells or provides a product or service to Tommy.


Tommy is committed to reducing the risk of Modern Slavery within Tommy and its supply chain in accordance with the obligations set forth in the Modern Slavery Act (Cth) 2018.
Tommy requires all Suppliers to comply with the Act and this Policy. Suppliers are required to investigate and report to Tommy on the modern slavery and labour practices of its supply chains to ensure compliance with the Act.
Tommy is committed to implementing and maintaining effective systems and controls to ensure compliance. These include:
  1. Conducting risk assessments of its supply chain to determine areas with the highest risk of Modern Slavery
  2. Engaging directly with selected key Suppliers to assess the risk of modern slavery within the Supplier and its supply chain
  3. Ensuring contractual agreements includes compliance with the Act.
Tommy reserves the right to terminate any Supplier contract if there is deemed to be a breach of this Policy or the Act. If Modern Slavery has been identified within a Supplier this supply relationship will be terminated with immediate effect. Continuous improvement is a major focus within Tommy and this Policy may be amended as a result over time.

Communication and Awareness

Tommy will provide training on the Act on an annual basis for staff who are involved in the selection and management of Suppliers.

Breaches of this Policy

Tommy recognises that some suppliers may have to work towards compliance with this Policy. Tommy may work with Suppliers to achieve compliance or if compliance cannot be achieved Tommy may terminate the trading arrangement.


The Tommy Associates Audit and Risk Committee has the overall responsibility for this Policy as well as the responsibility for ensuring Tommy’s reporting and compliance with the Act.
The Tommy Associates Finance Director, the General Counsel and the Head of Risk & Audit have the primary operational management responsibility for Tommy’s compliance with this Policy.
Tommy Associates Pty Ltd is not subject to the Modern Slavery Act 2018 (Cth) that commenced operation on 1 January 2019 though as a leader in our industry, Tommy Associates recognises the importance of our commitment to ensure the operation of our business is done in an ethical and lawful manner by ensuring we only work with those businesses who are aligned to our core values.
Tommy expects our suppliers to operate in accordance with all applicable modern slavery laws including those prohibiting human slavery and slavery like practices, human trafficking and child labour. We value and observe all laws regarding corporate social responsibility, environmental and workplace safety protection and staff inclusion and diversity

Reporting Non-Compliance

Suppliers may report suspected violations of this Policy to the Tommy Associates Audit and Risk Committee:
Mail: PO Box 583, Sanctuary Cove QLD 4217, Australia