Modern Slavery Policy


Ever Nimble values human rights and freedom. We stand firmly committed to maintaining the highest standards of ethical, professional, and legal conduct.

Our Modern Slavery Policy aims to ensure we prevent, detect and mitigate issues or risks of Modern Slavery, including educating our staff to enable them to play a crucial role in Ever Nimble achieving our goals and commitments.

This Policy assists in the Company meeting with its compliance obligations under the Modern Slavery Act 2018 (Cth) and provides an overview of the approach EN follows in respect of Modern Slavery practices.


This policy applies to all employees, consultants, contractors, partners, or other persons working with or on behalf of Ever Nimble. This Policy should also be read in conjunction with the Code of Conduct.

Modern Slavery

Modern Slavery as defined by the Modern Slavery Act 2018 (Cth), is a crime and a violation of fundamental human rights, and is a term used to depict a range of exploitive practices including:

  • Human trafficking
  • Slavery
  • Servitude
  • Forced labour
  • Debt bondage
  • Forced marriage, and
  • Child labour

EN recognises that modern slavery distorts global economies, affects corporate social responsibility and has devastating social impacts on the community.


EN has a zero-tolerance approach to any imposition of, or connection to, modern slavery or exploitation. This policy reflects our commitment to acting ethically and with integrity in respect of our employees, business relationships and the community in general, and to implementing and enforcing systems and controls to prevent and identify Modern Slavery.

EN is committed to ensuring that we, our supply chain, contractors, partners and other key stakeholders, are not engaged in or connected to modern slavery. We will do this through:

  • Conducting regular audits of wages, salaries and employment conditions of our employees to ensure compliance with workplace laws.
  • Regularly (annual) undertaking a review of the business to identify areas of greatest risk and taking appropriate preventative actions
  • Ensuring suppliers and partners hold or adopt policies and procedures to prevent indirectly contributing to modern slavery as part of contractual conditions.
  • Ensuring key personnel in relevant parts of the business understand, manage and regularly report on risks to the Director
  • Ensure our tender process includes the modern slavery questionnaire for any new suppliers and there are contractual obligations to address and meet modern slavery compliance included in any agreements
  • Taking immediate remedial action where any issues or concerns are identified. This includes seeking to first understand the cause of the issue, and whether or not we can take necessary steps to avoid further issues, or whether certain contracts or relationships need to be terminated.

What might modern slavery look like?

EN employees, partners, representatives, agents and others through whom EN conducts business with must not engage in any practice that constitutes any form of Modern Slavery. This includes, but is not limited to, the following activities:

  • Using forced labour in the performance of any work.
  • Using misleading or fraudulent practices during the recruitment process, including;
    • failing to disclose in a format and language accessible to the potential candidate, basic information relating to the role, or making material misrepresentations during the recruitment of candidates.
    • Providing false information relating to the key terms and conditions, including; wages and fringe benefits, the location of work, the living conditions, housing and associated costs, any significant cost to be charged to the candidate, and, if applicable, the hazardous nature of the work.
  • Engaging the use of recruiters that do not comply with local labour laws of the country in which the recruiting takes place.
  • Charging applicants / candidates recruitment fees.
  • If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work document in writing

Our Risk Areas

Supply Chain

We have a relatively simple supply chain. We procure goods and services needed for our business’s day-to-day operations from many contracted distributors and preferred suppliers operating in Australia, America and the UK.

Our long-term strategic relationships with key suppliers, provides a stability in our supply chain and procurement processes.

With a vast majority of our supplier’s operations being based in Australia and the UK we believe these suppliers have no risk within their business, and a lower risk of modern slavery occurring in their supply chains. This is based on the fact Australian and UK businesses are required to comply with the Modern Slavery Act within their own supply chains and have strict legislative conditions for their workforce.

Where we identify high-risk suppliers who are either located in or source their goods from high risk countries, we will request these businesses to complete a Modern Slavery Supplier Questionnaire. The responses we receive will identify the risks and require indication of implemented adequate steps to mitigate these risks.

Our workforce

We believe there is no risk of modern slavery in our directly employed workforce, as the labour market in Australia is highly regulated, and strict regulations apply. Our whistle blower policy and other policies outline procedures and communication pathways for employees, and other key stakeholders to disclose misconduct or any issues within our business without recrimination.


Anyone who suspects EN has breached this Policy must immediately notify:
Shiv Owen
Team Lead – Business Support

An individual can make an anonymous disclosure in accordance with the Company’s Whistle Blower Policy.

Breach of Policy

Any breach of this Policy will be taken seriously and conduct in contravention of this Policy may be regarded as misconduct, leading to disciplinary action. An individual may also be exposed to criminal or civil liability for breaching the Act.

Corporate governance

Ever Nimble will continue to review our policies and procedures to ensure that we have sound governance processes in place to meet our modern slavery compliance requirements. The Executive team will review and update this policy regularly at their Discretion.