Level 18/1 Nicholson St, East Melbourne VIC 3002

Modern Slavery

1.0 Modern Slavery And Human Rights Policy

Adaps is committed to ensure that its business dealings are conducted in compliance with the relevant laws and, in doing so, we endorse the implementation and promotion of ethical business practices to protect employees and workers from being abused and exploited.

Adaps is committed to preventing slavery and human trafficking in its corporate activities and to ensuring that its supply chains are free from slavery and human trafficking.

This is the Modern Slavery and Human Rights Statement (“Statement”) for Adaps, as informed by the Federal Modern Slavery Act 2018. The purpose of this statement is to outline our approach to ensuring that Adaps has robust framework and processes in place to minimise the risk of modern slavery in our business operations.

At Adaps, we recognize that slavery and human trafficking can occur in many forms, as considered in the Act. This can include slavery, servitude, human trafficking, forced marriage, forced labor, debt bondage, child labor, and deceptive recruiting for labor or services.

Adaps is fully committed to operating responsibly and establishing and adhering to the highest ethical standards across our group. We will not tolerate any forms of slavery or human rights in our business.

2.0 Human Rights

Adaps has a commitment to be a responsible global business, recognising the importance and advancement of Human Rights as an issue that is integral to our core business, our operations and us as employers across all our entities.

We will be communicating annually on the progress we make against the guiding principles, which cover human rights, labour standards, environmental protection, and anti-corruption.

Adaps operates a suite of policies adopted that reflect and embed its commitment to human rights. In 2019, we also formed a Sustainability Committee tasked with furthering environmental, social and governance interests within and external to the Adaps. As part of this in 2021, we developed an internal Contractor Care Team to monitor employee’s safety, concerns, and feedback, which included sections specifically on our employees, clients, human rights, and supply chain to ensure and to identify where risks may lie and how we can improve. In 2021, we will work to improve our policies and procedures to ensure best practice is shared amongst the Adaps, Adaps also being sensitive to local regulations and legislation worldwide. This is part of our continued commitment to human rights.

We respect human rights standards for the workforce of employees and our suppliers and promote sustainability standards in our recruitment process and supply chain. We share best practice widely across the Adaps, we ensure clients of the Adaps are treated fairly and data privacy always protected.

As an employer we respect international human rights standards. At present all Adaps entities are in jurisdictions which have equivalent to the Universal Human Rights. The Group promotes fair reward and recognition, diversity, inclusion, and equal opportunities in all employee dealings including decisions on hiring, remuneration, training, and promotion.

To date no infringements on human rights have been reported, but should a human rights risk be identified, we will involve the Adaps sustainability committee to ensure the Recruitment and services including risk, operations, and communications to address and mitigate future human rights risk.

At Adaps, we have listed below listed points to action on Human rights and Slavery: 

  • forced to work – through coercion, or mental or physical threat.
  • owned or controlled by an ’employer,’ through mental or physical abuse or the threat of abuse.
  • dehumanized, treated as a commodity, or bought and sold as ‘property.’
  • physically constrained or have restrictions placed on their freedom of movement. Forms of exploitation can range from forced prostitution and forced labor to forced marriage and forced organ removal.
  • Forced labor – any work or services which people are forced to do against their will under the threat of some form of punishment.
  • Debt bondage or bonded labor – the world’s most widespread form of slavery, when people borrow money, they cannot repay and are required to work to pay off the debt, then losing control over the conditions of both their employment and the debt.
  • Human trafficking– involves transporting, recruiting or harboring people for the purpose of exploitation, using violence, threats, or coercion
  • Discrimination
  • harsh and inhumane treatment
  • Child Labor
  • excessive working hours
  • poor, unhygienic or unsafe working conditions
  • Equal Employment options

2.0 Code Of Conduct

Our Code covers a range of essential elements about how we do business, including key elements on behaving ethically and lawfully. It also outlines where to go for further help, and how to raise concerns through various channels, including our whistleblowing service. Our Board, CEO and Leadership Team are deeply committed to our Code. It helps us take a consistent, global approach to important ethical and compliance issues.

2.1 Supplier Code Of Conduct

Adaps & Company (“Adaps”) is committed to the highest standards of integrity and social responsibility, and Adaps expects all its Suppliers engaged in providing products and services to Adaps (“Suppliers”) to have, or to make, a similar commitment. The Adaps Supplier Code of Conduct (“Code”) describes Adaps expectations of how its Suppliers conduct business. Adaps expects Suppliers to act in accordance with the Code, and at a minimum requires that all Suppliers comply with applicable laws and regulations within the geographies where they operate and be open and cooperative with the regulators enforcing such laws. In instances where expectations outlined in the Code differ from local laws, Suppliers must follow these expectations within the bounds of applicable local laws.

Adaps does not tolerate slavery, forced labor, or human trafficking in any form. Adaps requires Suppliers to fully comply with the applicable legal requirements of slavery, forced labor and human trafficking laws (e.g., Human Rights and Modern Slavery Act 2018), and expects Suppliers to enact practices to ensure compliance with such laws.The Code reflects Adaps values and sets forth what it expected of its Suppliers with respect to the following Areas:

  1. Ethics and integrity
  2. Data privacy and security
  3. Inclusion and diversity
  4. Employment and working conditions
  5. Wellbeing, health, and safety
  6. Environment
  7. Child Labor must not be used
  8. Human Rights
  9. Freedom of association and the right to collective bargaining are respected.
  10. Living wages are paid
  11. Working hours are not excessive
  12. No discrimination is practised
  13. Regular employment is provided
  14. No harsh or inhumane treatment is allowed
2.2  Employee Code Of Conduct

We are committed to acting with integrity in all our business dealings and complying with laws. Many of our existing policies are aimed at ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We require everyone that works for Ellucian to respect these values, which ensure that we respect all individuals and that we comply with all laws (including the Modern Slavery Act).

Adaps Code of Conduct makes clear to employees the actions and behavior expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behavior when operating abroad and managing its supply chain. Adaps HR Team will communicate with all the employees on the code of conduct and take the sign from each one and maintains the record as part of the joining formalities.

Adaps will ensure that the recruitment process, including the use of recruitment or placement agencies, may be a risk in term of modern slavery. We engage and work in collaboration with our recruitment or placement agencies to ensure no fees or costs are incurred to candidates.

3.0 Our Policies And Procedures

We have formal policies already in place that are intended to promote ethical and legally compliant business conduct. Our policies contribute to our commitment to prevent violations of human rights such as modern forms of slavery in our business including our Code of Conduct, Speak Up (whistleblower) Policy and anonymous Ethics Hotline.

3.1  Whistleblowing Policy

Adaps encourages all its workers, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. To this end, the Adaps has an Incident Report form shared with the employees in SharePoint, via which anyone can report an incident which may ‘negatively impact the business, our employees (individually or collectively) or our reputation.’ The Group’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, who have concerns can use our confidential helpline through contractor care team, an independent reporting line, which is widely advertised across Adaps and monitored by our Board. Alternatively, disclosures can be reported by notifying their line manager, who will conduct or arrange for a senior individual to investigate or notified directly to either our HR Team or Contractor care team. Otherwise, the individual may deem it appropriate to contact a legislative body. Across both disclosure routes, no calls or direct disclosures were made in 2020 in relation to modern slavery and trafficking.

Our Procurement team have several risk mitigation and robust procurement processes in place including our Supplier Engagement Principles and supplier on-boarding requirements.

3.2 Recruitment Policy

Adaps will ensure appropriate controls are in place to ensure employees have the right to work and are therefore protected by employment legislation. This includes checking right-to-work documents, visas, and passports. Additionally, we also verify that employees have supplied a proof of address/residence. Adaps is also actively adopting more inclusive hiring practices, globally, through increasing line manager awareness and accountability of unconscious bias in the hiring process and therefore driving a more objective recruitment process. We are also sourcing candidates through more diverse job boards, aiming to increase representation in the workplace. Likewise, Adaps uses only specified, reputable employment agencies to source labor. To ensure this, we mandate that agencies for both temporary and permanent workers enter into our agreements which place obligations on those agencies to comply with all applicable laws (including Human rights and modern slavery legislation), provide us with their Human rights and modern slavery policy (where applicable) and carry out all appropriate checks on workers. Additionally, we conduct annual business reviews with our recruitment agencies to ensure compliance and alignment to our Adaps goals and values.

Adaps does not employ individuals that would be ‘child workers. Young and inexperienced workers may be employed or given work experience, but they are subject to the rights and protections that we afford all workers.

Basic rights which we expect all employees to have access to, include:

  • All recruitment decisions are consistent with the Adaps values
  • The process is consistently and fairly applied
  • We act in accordance with the principles in our redundancy and redeployment policy as well as our diversity and inclusion policy
  • The right to a reasonable wage
  • The right to a safe working environment
  • The right to an appropriate level of holiday and cover for period of sickness
  • The freedom to complain directly or via our whistleblowing policy free of charge.

If employees believe that they are not being fairly treated or have any other concerns. The above is all monitored by the respective HR Business Partners, Contractor care team. Our contractor care team will ensure that all employees have access to the whistleblowing policy and contact number and email id. In 2020, there were no breaches of basic rights reported

We have a formal recruitment process for both our permanent and contingent workforce that all recruiters are required to follow. All the above procedural controls will be reviewed to ensure that we have robust processes in place to minimize the risk of modern slavery in our operations.


Our Code sets out the standards of behavior we expect of our people, including our directors, employees, and contractors. It embodies our commitment to good corporate governance and responsible business practice. It also reflects the expectation of our customers, investors, regulators, and the community.

Our contractor care team will take the feedback from each employee once in a year or on need basis with the following questionnaire.

An example of some of the questions in the survey has been provided below.

  • Our physical workspace is enjoyable to work in
  • I have access to the things I need to do my job well
  • I believe my total compensation (base salary/any bonuses/benefits/equity) is fair
  • Adaps commitment to social responsibility is genuine
  • Workloads are divided fairly among people where I work
  • Adaps is truly a People First organisation
  • If I raise a concern about an individual’s behaviour, I am confident that the appropriate action will be taken
  • We have enough autonomy to perform our job’s effectively
  • I receive appropriate recognition for good work at the Group
  • We are genuinely supported if we choose to make use of flexible working arrangements
  • I can arrange time out from work when I need to
  • Genuinely, I believe my workload is reasonable for my role

Throughout FY20, employee Wellbeing was an important focus for us, especially through the global pandemic. We launched a Covid insurance policy for our employees early in FY20, who were trained on Covid precautions. As the global pandemic impacted, we provided a range of supportive guides and webinars through the initial stages of the pandemic to help employees. We made HR policy enhancements to offer more support considering the challenges employees were facing, including work from home and up to 10 days of paid leave for who has been suffered with the covid.


To help ensure a consistent approach to managing human rights risks, including those related to modern slavery, we have a human rights compliance plan which includes obligations relating to our most salient human rights risk areas.

Risk Areas

 Adaps continues to review and categorize its risks in Recruitment and supply chain and ensure this information is shared across Adaps. For example, following modern slavery training, recruitment has been identified as an area of potential risk requiring specific focus, and we will be reviewing the contracts we have in place with all our preferred recruitment partners to ensure our approach to modern slavery is fully incorporated. We have created a set of procurement principles that have been shared with all key subsidiaries.

The compliance plan requires each business function to identify and assess their operations and supply chain for human rights risks and to implement appropriate controls, with the business encouraged to integrate these into existing processes. We have defined controls for human rights risk in our operations and incorporated those into our compliance management framework.

Our compliance program will continue to develop as our approach and understanding matures. Our focus for this coming year will be on ensuring it is aligned with the requirements of the Modern Slavery Act 2018.

6.0 Supplier Management

Adaps exercises a vital role in the supplier engagement, it does not have a supply chain that is reliant on factories or other entities that would normally be associated with slavery or forced labor.

Contractors and suppliers used by the Adaps are therefore not likely to be susceptible to this risk. However, we are mindful that others may not always uphold standards to the same level as the Adaps. Consequently, employees responsible for managing suppliers and others involved with the Adaps are, themselves, responsible for ensuring that our values and ideals are upheld. This continues to be a work in progress, and we are strengthening our controls as new contracts are agreed, this includes modern slavery questions within our due diligence questionnaire and training/raising awareness communications amongst employees. At present we are undertaking a due diligence process for supply for the critical suppliers. For example, serious violations by suppliers may lead to the termination of the business relationship, to date this has never occurred.

We work with our suppliers to assess whether they are meeting our standards. Many of our suppliers have processes in place for managing their own risks and are open to working with us to meet our minimum standards. Where we identify concerns about supplier performance, we engage with the supplier, seeking constructive dialogue and remediation of non-compliance with our standards.

Where suppliers are unable to satisfy us that they have appropriate risk management controls in place, or are unwilling to share this information, we may take further action, such as engaging supplier senior management, implementing a remediation plan, or suspending the services.

We expect our suppliers to monitor their own, and their suppliers’ compliance with our Supplier Code of Conduct and to correct any identified deficiencies in a timely manner. We also require them to notify us if they become aware of an actual breach or reasonable likelihood of breaching of the Code.

We work with our suppliers to assess whether they are meeting the Code in several ways, such as governance meetings and reports, questionnaire and audits. The approach we take is based on the nature of the risks, and the category of the goods or services being provided.

6.1 Terms And Conditions Of The Suppliers

The Supplier must ensure to follow below criteria for any services they provide, and we shall ensure to take the signed copy from the suppliers for each requirement on need basis:

(a) comply with applicable anti-slavery and human trafficking Laws, including, without limitation, the Modern Slavery Act 2018 and any applicable equivalent Laws in Australian states and territories.

(b) not engage in and must use reasonable endeavours to ensure that Supplier’s Personnel and
Supplier’s own suppliers do not engage in, Modern Slavery.

(c) implement appropriate policies, measures, and processes to ensure compliance with its obligations under this clause, and to identify and address the risks of Modern Slavery in its operations and supply chains.

(d) upon request, provide to Adaps evidence confirming to Adaps satisfaction that the Supplier has complied with this clause; and

(e) notify Adaps as soon as reasonably practicable of any instance of Modern Slavery
identified in the Supplier’s operations or supply chains, and any steps the Supplier has taken, or
proposes to take, in response to the instance of Modern Slavery.

7.0  Grievance Mechanisms

7.1  Whistleblowing

By law, certain protections may apply to a range of people, including current and former employees, their relatives and dependents, and suppliers and their employees to report concerns about unethical, illegal, or improper behavior, or about an improper state of affairs at Adaps. Our Whistleblowing Policy is supported by a confidential process that provides appropriate protections for anyone to report their concerns, a Whistleblowing Service where people can report their concerns anonymously and professional investigators and case managers.

7.2  Reporting And Performance Indicators

We monitor, manage and report progress on a range of indicators used to assess the effectiveness of our responsible business programs and performance.

We recognize our influence and impacts go beyond our own operations and therefore, our performance indicators extend along our value chain, from our supply chain through to our operations and onto our customers and the community.

8.0  Future Commitments

Over the next year, our key focus areas will be:

  • Reviewing and updating our suite of risk-related policies and governance control measures.
  • Begin stakeholder engagement on this issue, including delivering appropriate awareness training sessions on modern slavery and Human Rights principles to relevant ADAPS staff, our franchisees, and key suppliers.
  • Incorporating requirements into existing assurance processes and
  • Preparing our first reporting cycle under the Act and if appropriate under the NSW Modern Slavery Act 2018.

This statement was approved by the Board of Adaps.