Modern Slavery Policy

Omega Medical - Modern Slavery Policy


PURPOSE

Omega Medical is committed to preventing Modern Slavery in all its forms. Modern Slavery is a serious violation of human rights and includes conduct such as trafficking in persons, slavery, servitude, forced labour, forced marriage, debt bondage, deceptive recruitment, and the worst forms of child labour, as defined in the Modern Slavery Act 2018 (Cth).

The purpose of this policy is to:
• Set out Omega Medical’s commitment to identifying, reducing, and managing Modern Slavery risks in our operations and supply chains
• Ensure robust systems are in place to prevent, detect, and respond to Modern Slavery concerns
• Promote transparency and compliance with the Act and community expectations
• Support ethical, fair, and safe work practices for all workers involved in our business
• Outline clear processes for remediation, monitoring, and accountability


GROUP STRUCTURE

Omega Medical is a provider of staffing and recruitment services to a wide range of clients in the healthcare sector. The company has its registered office in Sydney, Australia, and has over 40 employees across our Sydney and Gold Coast offices. The Managing Director is responsible for oversight of this policy.

Omega Medical purchases a wide range of products and services from its supply chain, including:

  • IT hardware, software, and telecommunications
  • Office furniture, equipment, and supplies
  • Utilities, travel services, and training services


SCOPE

This policy applies to all Omega Medical employees, directors, officers, volunteers, interns, labour-hire workers, candidates, contractors, suppliers, and third-party business partners engaged by or on behalf of Omega Medical.


POLICY STATEMENT

Omega Medical has a zero-tolerance approach to Modern Slavery.

Omega Medical 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 operations or supply chains.

Omega Medical is also committed to ensuring there is transparency in its approach to tackling Modern Slavery throughout its business and supply chains, consistent with Omega Medical’s disclosure obligations under the Act.

The prevention, detection and reporting of Modern Slavery in any part of Omega Medical’s business and supply chains is the responsibility of all those working for it or under its control.

 

Omega Medical expects the same high standards from all of its contractors, suppliers and other business partners.

We meet with prospective candidates (wherever reasonably possible) and carry out a number of checks on prospective employees and candidates (whether they are to be placed with clients or for our own internal recruitment purposes) as part of our due diligence processes. Depending on the nature of the relationship held we:


  • conduct Right to Work and reference checks on our employees and candidates as applicable
  • check that temporary workers who we payroll have their own bank account into which they can be paid and receive pay that is compliant with the relevant legislation in the applicable jurisdiction
  • engage temporary workers via a formal contract which is compliant with relevant legislation in the applicable jurisdiction
  • comprehensively vet and audit umbrella companies to ensure that those on our preferred supplier list comply with all relevant laws in the applicable jurisdiction relating to employment and taxation


Overall, we consider that the nature of the recruitment services that we provide, and the sectors within which we operate, mean that our risk of slavery is lower than in other sectors. However, our Board will continue to monitor the risk and revisit this assessment on a yearly basis.


DUE DILIGENCE AND RISK ASSESSMENT

Omega Medical maintains a structured due diligence process to identify, assess, and address Modern Slavery risks. We:
 • Conduct risk assessments of new and existing suppliers and business partners
 • Undertake Right to Work and reference checks on employees and candidates
 • Ensure all workers are paid into their own bank accounts and are engaged under compliant contracts
 • Vet and audit umbrella or payroll companies to ensure compliance with workplace and taxation laws
 • Require suppliers to demonstrate their own Modern Slavery policies or equivalent controls
 • Monitor and review risk factors annually through our Board risk and compliance process

While our risk profile is considered low due to the nature of our business, our leadership team remains committed to continual review and improvement.


ROLES AND RESPONSIBILITIES

  • Managing Director: Overall accountability for compliance and risk management   
  • HR: Training, reporting pathway management, candidate and worker due diligence   
  • Managers & Leaders: Escalate concerns, support monitoring of suppliers and labour practices   
  • All Workers: Identify and report suspected Modern Slavery risks or behaviours   


OUR OPERATIONS & SUPPLY CHAIN

Omega Medical provides healthcare recruitment and staffing services across Australia. Our supply chains include:

·      Technology and telecommunications providers

·      Office equipment, utilities, travel and training services

·      Professional services (accounting, legal, IT)

·      Umbrella and payroll companies, where applicable

Given our industry, we acknowledge lower exposure than some sectors, but we recognise heightened risk in:

·      Labour supply chains

·      Outsourced payroll or labour-hire arrangements

·      International sourcing of goods or services


SUPPLIER & CONTRACTOR EXPECTATIONS

Omega Medical will only work with suppliers and partners who share our commitment to ethical labour practices. We may require suppliers to:

·      Comply with this Policy and the Supplier Code of Conduct

·      Demonstrate they have their own anti-slavery controls

·      Participate in audits, reviews or information requests

·      Include Modern Slavery clauses in contracts

Omega Medical reserves the right to terminate relationships with suppliers who breach or refuse to comply with our ethical standards.


RECRUITMENT CANDIDATE WELFARE & DUE DILIGENCE

To protect workers, we will:

·      Conduct Right to Work and identity checks on all candidates

·      Meet candidates where reasonably possible to verify legitimacy

·      Ensure workers are paid into their own bank account

·      Ensure all labour-hire arrangements comply with workplace and taxation laws

·      Avoid deceptive recruitment practices under any circumstance


REMEDIATION AND BREACH MANAGEMENT

Where Modern Slavery risks or breaches are identified, Omega Medical will:
 • Investigate concerns promptly and fairly
 • Engage with affected individuals to ensure appropriate remedy and protection
 • Take disciplinary or contractual action where suppliers or staff breach this policy
 • Work with authorities and external partners as required
 • Record, monitor, and report remediation actions to senior management


REPORTING MODERN SLAVERY CONCERNS

Anyone can report suspected Modern Slavery. Concerns should be raised as soon as possible through one of the following channels:

Internal reporting:

·      HR

·      Managing Director

·      Whistleblower channels (where applicable)

External reporting:

·      Australian Border Force (Modern Slavery Unit)

·      Crime Stoppers

·      Police or emergency services (000) where life or safety is at risk

Reports will be handled confidentially, and retaliation against a person raising a concern in good faith is strictly prohibited.

 

INVESTIGATION AND RESPONSE

Omega Medical will:

Investigate all reported concerns promptly and fairly

Take corrective action where risk or harm is identified

Work with authorities where appropriate

Document, track and monitor remediation actions


TRAINING FOR STAFF

Omega Medical provides annual mandatory training to help employees recognise and report Modern Slavery. This training is part of our compliance induction and ongoing learning programs.

We also encourage our suppliers and contractors to undertake training on modern slavery risk and prevention — including attending HealthShare Victoria’s “Introduction to Modern Slavery Risk” and other relevant supplier engagement sessions.


MEASURING EFFECTIVENESS

Omega Medical reviews and measures the effectiveness of this policy and associated processes through:
 • Supplier audits and compliance reviews
 • Recruitment and payroll compliance checks
 • Training completion rates and feedback
 • Tracking and resolving reported incidents
 • Annual review by the Board and HR


RECORDS MANAGEMENT

• The current approved version of this policy will be stored on Employment Hero.
 • HR will maintain records of training, due diligence, reports, and remedial actions.
 • This policy will be reviewed annually or sooner if required by law or organisational change.


LOOKING AHEAD

Modern slavery risk management requires continuous commitment and ongoing collaboration. This is both from within our company and through ongoing, multi-stakeholder dialogue in international and domestic policy forums, the World Health Organisation and with local governments of host countries.


RELATED POLICIES

Employees and staff are encouraged to read this policy in conjunction with other relevant Company policies including Whistleblower Policy, Disciplinary Policy, Code of Conduct.


LEGISLATION

Modern Slavery Act 2018 - https://www.legislation.gov.au/Details/C2018A00153