Modern Slavery Policy

NATURO GROUP PTY LTD ATF Hanelg Trust ("Naturo Group", "we") does not tolerate modern slavery in any form, in our own business or in our supply chain. This policy sets out how we identify, prevent and respond to modern slavery risks.

1. Purpose and scope

Modern slavery includes slavery, servitude, forced labour, debt bondage, deceptive recruiting, human trafficking and the worst forms of child labour, as described in the Modern Slavery Act 2018 (Cth). Our annual revenue is below the Act's mandatory reporting threshold; we adopt this policy voluntarily and to support customers that report under the Act.

This policy applies to our directors, employees, contractors and subcontracted cleaners, and to the suppliers we buy goods and services from.

2. Our operations and supply chain

Naturo Group provides residential, commercial, NDIS, aged care, DVA and insurance cleaning services from bases in Port Macquarie (NSW) and Geelong (VIC). Our workforce is Australian based. Our main purchases are cleaning chemicals, equipment and consumables (such as gloves, cloths and bags), vehicles and fuel, uniforms, software and professional services.

3. Where the risks are

We recognise the following areas carry a higher risk of modern slavery:

• Cleaning labour. The cleaning industry is recognised as high risk for underpayment, sham contracting and exploitation of vulnerable and visa-holding workers, particularly through subcontracting and labour hire.
• Disposable gloves. Rubber and nitrile glove manufacturing has a documented history of forced labour and recruitment-fee debt bondage.
• Textiles. Cotton and microfibre cloths, mops and uniforms can be sourced from regions with known forced-labour concerns.
• Cleaning products and equipment manufactured overseas with limited visibility of the production chain.

4. What we do

Our workforce

• We pay at least the minimum rates under the Cleaning Services Award, keep accurate time and pay records, and pay superannuation.
• We verify each worker's identity and right to work in Australia before they start.
• We never charge recruitment fees and never hold workers' passports, identity documents or wages.
• Workers are free to end their engagement with notice and are not bound by debts to us.
• We hold the registrations required for our services, including Portable Long Service Leave registration for contract cleaning in Victoria.

Our suppliers

• We prefer established Australian suppliers that publish their own modern slavery statements or policies.
• We expect suppliers and subcontractors to comply with this policy and with Australian workplace law, and we will ask for information about their practices where a risk is identified.
• We do not engage labour hire or subcontracted cleaners who are not appropriately licensed or registered.

5. Training and awareness

Managers responsible for hiring and purchasing are made aware of modern slavery risks and the warning signs, and this policy is shared with all staff and contractors when they join.

6. Reporting concerns

Anyone can raise a concern, anonymously if they prefer, by emailing admin@naturogroup.com.au or calling 1300 876 472. We will not penalise anyone for raising a concern in good faith. Concerns may also be reported to the Australian Federal Police on 131 237, or to the Fair Work Ombudsman on 13 13 94.

7. How we respond

We will investigate every concern promptly. If we find modern slavery in our operations or supply chain, we will put the safety of the people affected first, work to remedy the harm, report to the authorities where appropriate, and end the relationship with any supplier that will not address the issue.

8. Responsibility and review

The Director of NATURO GROUP PTY LTD ATF Hanelg Trust is responsible for this policy. We review it at least once a year, and whenever our operations or supply chain change significantly.