Policy owner and approver: Adam Cogan
Last updated: 15 October 2026
SSW respects human rights and is committed to preventing modern slavery in our operations and supply chains. Everyone should be able to work freely, safely and with dignity.
This policy applies to SSW's operations worldwide, including employees, managers and contractors. We expect suppliers and business partners to meet these standards in their dealings with us and their own supply chains. Local legal requirements take precedence where necessary.
This policy sets out our commitments and operating practices. It is not an annual Modern Slavery Statement under the Australian Modern Slavery Act 2018 (Cth).
Modern slavery involves serious exploitation where a person cannot refuse or leave because of threats, coercion, deception or abuse of power. It includes slavery, servitude, forced labour, debt bondage, human trafficking, forced marriage and the worst forms of child labour.
Warning signs can include withheld identity documents, recruitment debts used to control workers, threats, restrictions on movement or workers being unable to leave their employment freely.
SSW requires work to be voluntary and employment terms to be clear. We do not tolerate forced labour, unlawful child labour, coercive recruitment practices or withholding identity documents to control workers. Workers must receive their lawful pay and entitlements and be able to raise concerns without retaliation.
Adam Cogan is responsible for this policy. Managers must support its implementation and respond to concerns. Staff involved in procurement, recruitment and supplier relationships must consider modern slavery risks and escalate warning signs.
SSW conducts annual modern slavery risk assessments, supplier checks and audits. We consider risks in our own operations and supply chains, including relevant purchases and services such as technology hardware, cleaning, recruitment, labour hire and subcontracting.
Our approach is proportionate to the risk. Assessments should consider the type of work, location, recruitment arrangements, use of subcontractors and the vulnerability of affected workers. Where concerns arise, we seek further information and determine appropriate follow-up actions rather than waiting for the next annual assessment.
We expect suppliers and partners to:
SSW provides annual modern slavery training for employees and management to help them recognise warning signs, understand their responsibilities and report concerns. Our learning resources are delivered through SugarLearning.
Employees, contractors, suppliers and other affected people can report suspected modern slavery to Adam Cogan at [email protected]. If the concern involves Adam, or you are uncomfortable reporting to him, contact Levi Jackson at [email protected].
Staff may also speak with their State Manager or another State Manager. You do not need to raise a concern with your manager before using another reporting option. You do not need proof before reporting a reasonable concern, and you should not put yourself or another person at risk by investigating it yourself.
We handle reports sensitively and restrict information to those who need it to assess or respond to the concern, or where disclosure is required by law. We do not tolerate retaliation against anyone who raises a concern or assists an investigation. These reporting options do not prevent anyone from contacting relevant authorities or using protections available under applicable law. If someone is in immediate danger, contact local emergency services.
SSW will assess reports promptly, consider the safety and needs of affected people, and arrange an appropriate investigation. A person implicated in a concern must not control its investigation or outcome. We will involve appropriate authorities or specialist support where needed.
Where exploitation is identified, our response should prioritise protecting affected people and addressing the harm. Actions may include working with a supplier on corrective measures, checking that those measures are effective, or suspending or ending a relationship where appropriate. Decisions must consider whether disengagement could increase harm to workers.
Breaches by employees may result in disciplinary action, up to termination of employment, subject to applicable law and a fair process. Supplier and partner breaches may lead to contractual action. Findings from assessments, audits, training and reports inform improvements to our practices.