WMSHR.202609
Modern Slavery and Human Rights Policy
Westan Australia Pty Ltd and Westan (NZ) Limited
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Purpose
Westan is committed to conducting its business ethically and with respect for human rights. This Policy sets out our commitment to identifying, preventing and addressing modern slavery – including forced labour, human trafficking, debt bondage, child labour and worker exploitation – in our own operations and across our supply chains.
This policy supports the Westan Modern Slavery Statement [WMSS.202607] and reflects the principles of the Modern Slavery Act 2018 (Cth), which Westan follows on a voluntary basis.
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Scope
This Policy applies to:
- All Westan employees and directors, across our Melbourne, Sydney, Brisbane and Auckland operations
- Contractors, subcontract installers and repair agents engaged by Westan
- Suppliers, manufacturers and vendors whose products Westan distributes
- Logistics and freight providers used by Westan.
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Our Commitment
Westan does not tolerate modern slavery in any form, in any part of our business or supply chain. We are committed to:
- Assessing and addressing modern slavery risks on a proportionate, risk-based approach appropriate to our role as a multi-brand AV distributor
- Not engaging in, and not knowingly facilitating, forced labour, human trafficking, debt bondage, child labour or worker exploitation
- Requiring suppliers to meet the standards set out in our Supplier Code and Conduct
- Providing a way for concerns to be raised and properly investigated
- Taking corrective action, including ending a business relationship where necessary, if modern slavery risk is identified and not remediated.
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Roles and Responsibilities
Board of directors approves this Policy, oversees Westan’s overall approach to modern slavery risk, and approves the annual Modern Slavery Statement.
Head of Operations owns this Policy, oversees its implementation, leads supplier risk assessment and due diligence activity, and is the primary escalation point for concerns raised under this Policy.
All employees are expected to understand the indicators of modern slavery relevant to their role, follow this Policy and related procedures, and report any concerns promptly.
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Identifying and Assessing Risk
Westan does not manufacture products – our modern slavery risk sits primarily in the manufacturing and assembly supply chains of the brands we distribute and in subcontracted services (such as installation and repair) within Australia and New Zealand.
Westan has identified higher inherent risk in the following areas:
- Electronics manufacturing and assembly, particularly in regions with weaker labour law enforcement
- Component and accessory manufacturing
- Upstream raw materials used in electronics, where supply chain visibility is limited
- Subcontract installation and repair services, where labour may be outsourced further.
Westan’s own Australian and New Zealand operations are assessed as lower risk, given the regulatory and workplace protections in both jurisdictions. This risk assessment is reviewed periodically and updated as our supplier base or brand portfolio changes.
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Due Diligence
Westan applies a proportionate, risk-based due diligence approach appropriate to a distributor that does not control factory-level operations. This includes:
- Considering country and sector risk when onboarding new suppliers and reviewing existing ones
- Prioritising closer engagement with higher-risk suppliers and product categories
- Communicating our expectations to suppliers through contractual terms and our Supplier Code of Conduct
- Considering supplier-published modern slavery statements, certifications or disclosures as one input into our assessment, while recognising that these alone are not sufficient assurance
- Requesting further information from suppliers where risk indicators are identified.
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Recruitment and Labour Practices
Westan does not charge and does not permit recruitment, placement or similar fees to be charged to any employee, contractor or labour-hire worker engaged in connection with employment at Westan. Workers retain control of their own identity and travel documents and are free to leave their employment in accordance with applicable law. Westan’s Australian and New Zealand operations comply with applicable wage, working hours and employment law requirements in each jurisdiction. Westan expects the same standards from its subcontract installers, repair agents and other labour-hire arrangements.
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Training and Awareness
Westan provides guidance to relevant personnel – particularly those involved in supplier onboarding, procurement and operations – on recognising indicators of modern slavery, understanding escalation pathways, and engaging responsibly with suppliers. This guidance is refreshed periodically as this Policy and Westan’s risk assessment evolve.
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Reporting Concerns
Employees, contractors, suppliers and other stakeholders can raise concerns about actual or suspected modern slavery in Westan’s operations or supply chain by contacting the Head of Operations directly, or through the People & Culture department, for internal escalation.
Westan will treat all concerns seriously, investigate promptly and protect anyone raising a concern in good faith from retaliation.
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Remediation
Where Westan identifies a potential or actual modern slavery risk, we will assess the matter and respond proportionately. This may include working with the supplier or contractor to remediate the issue, requiring corrective action within a defined timeframe, or ending the business relationship where remediation is not feasible or the supplier is unwilling to cooperate.
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Review
This Policy will be reviewed at least annually, or earlier if Westan’s operations, supply chain or risk profile changes materially or, if relevant, legislation changes.
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Related Documents
Westan Modern Slavery Statement [WMSS.202607]
Westan Supplier Code of Conduct