Modern Slavery Policy
Effective July 2024.
Thank you for choosing to be part of our community at Aura Clean Energy.
Aura is committed to developing and maintaining a Modern Slavery policy and processes that demonstrate our commitment to the highest ethical standards. We view the take the existence of any Modern Slavery very seriously. In this policy, we seek to explain to you how we implement, maintain and continually improve our Modern Slavery Policy. Please read this policy carefully as it will help you understand Aura’s approach to this very important topic.
1. Purpose
The purpose of this policy is to describe the scope of the modern slavery policy, define accountabilities of all persons involved and to provide procedures for testing and inspection for all activities that may be exposed to the risk of modern slavery abuse. Aura’s Policy Directory is used to direct internal activities, and to inform external parties who require information about our quality systems.
A company appointed internal working group monitors the way we implement, maintain and continually improve our Quality Management Systems (QMS) which includes our Modern Slavery Policy. This process identifies the criteria and methods used to ensure the effective operation, and control of company systems, and identifies the monitoring, analysis, information, and actions necessary to achieve business outcomes.
Senior Management of Aura with input from the working group, determines the management of the external and internal issues that have an impact on the projects, products and services that we procure from our suppliers or deliver to our customers.
To understand the external issues, the Management Team monitors and considers issues coming from:
• Legal and legislative requirements
• Technology changes
• Client needs
• Market competition
• Supplied products and services
To understand the internal issues, the Management Team monitors and considers issues coming from:
• Aura’s values
• Aura’s culture and ways of operating
• Aura’s intellectual property
• The ongoing performance of the company against project plans, objectives and targets
2. Scope
Aura applies its QMS to the delivery of any product and/or service offered by Aura. Where any process or service is outsourced, Aura will determine criteria and methods of control to ensure conformity to customer and regulatory requirements
3. Statement of commitment
Aura acknowledges that commercial business operations plays an important role in promoting and upholding human rights towards completely eradicating modern slavery. At Aura, we recognise that modern slavery is a growing and complex problem, best tackled by collective commitment and responsibility to bring it to an end and we are committed to working with all our stakeholders to fulfil this common goal.
If we uncover the use of Modern Slavery, we will act as quickly as practicable to remedy its adverse impacts on workers, individuals or communities and we will engage directly with affected stakeholders.
We understand that the Australian Modern Slavery Act 2018 (the Act)took effect on 1 January 2019 and does not require Aura to make annual public reports (Modern Slavery Statements).
4. Project quality assurance
Quality assurance for an Aura project will be achieved by defining the relevant quality project management processes that will be applied in each particular instance. In relation to Modern Slavery this policy is to be read in conjunction with AP-014 Project Quality Management Policy 2019. (Please contact us for further details).
5. Methodologies and standards
Proven methodologies and standards will be used to ensure that quality project management processes are being applied. The relevant methodologies, standards and guidelines will include:
• Conduct regular due diligence to ensure that Aura is compliant with local, national, and other applicable laws and regulations in the areas in which the businesses operate,
• Source products and services in accordance with legal obligations and community expectations while seeking reassurance from suppliers that their social and environmental practices are best practice, that they act to prevent, mitigate and where appropriate, remedy modern slavery in their operations and supply chains,
• Implement procedures to ensure that we are addressing modern slavery and ethical sourcing risks in our operations and supply chains,
• Include in our operational and supplier contract terms, requirements that suppliers comply with all local, national and other applicable laws and regulations in the areas in which they operate,
• Ensure that we maintain the rights of termination if the supplier is unable or unwilling to work towards full compliance with the minimum standards with regards to the Act,
• Have a modern slavery risk management process implemented that includes regular reviews of our approach to eradicating the use of Modern Slavery in the supply chain. Refer also AP-019 Risk Management Policy 2019.
6. Project evaluation
When modern slavery management is being undertaken effectively in an Aura project, this will be facilitated by building in regular reviews of both output development processes and project processes.
Therefore:
• Reviews will be conducted at the beginning of a phase or each and every phase, and/or after all outputs have been delivered prior to the project being close
• Reviews will cover:
o A review of project performance against the defined project modern slavery protocols
o A review of the processes used to produce the outputs
• Senior Management of Aura will determine:
o Who is responsible for arranging and managing the review
o Who will perform the review
o Who is responsible for the post implementation review process
o Who will the report be delivered to
o Who is responsible for accepting the reports produced by the process
o Will all relevant stakeholders be included within the review process?
o What action will be taken once the report(s) have been received?
• All reviews will be conducted in accordance with Aura’s QMS reviews process
7. Document Review
This policy will be reviewed annually and/or in line with legislative changes.
