Guideline - GOV 01.03.03 - Human Rights and Modern Slavery 

1.0 Purpose

Altus Group is committed to respecting and promoting fundamental human rights and the eradication of modern slavery in all its forms. This guideline outlines our responsibilities, expectations, and approach to:

a) Supporting and upholding internationally recognised human rights across all our operations and value chains.

b) Ensuring the goods and services we procure are free from slavery, servitude, forced labour, deceptive recruiting, human trafficking and child labour.

c) Guiding our personnel and stakeholders to prevent, identify, and respond to human rights and modern slavery risks.

This commitment is aligned with the Ten Principles of the United Nations Global Compact, which guide our efforts across four key areas:

d) Human Rights (Principles 1 - 2)

e) Labour (Principles 3 - 6)

f) Environment (Principles 7 - 9)

g) Anti-Corruption (Principle 10)

These principles serve as a global framework to embed sustainability and ethical business conduct into our corporate strategy, operations, supply chains, and stakeholder relationships.

The Board and Senior Leadership support this guideline, which complements our Code of Conduct, Supplier Management, and Whistleblower Policies and Guidelines. This guideline also aligns with the United Nations Guiding Principles on Business and Human Rights (UNGPs), which define our corporate responsibility to respect human rights, avoid contributing to abuses, and address adverse impacts.

 2.0 Scope 

This guideline applies to: 

a) All Altus Group employees, directors, officers, contractors, consultants, and subsidiaries globally. 

b) All business operations, activities, services, and supply chains. 

c) All third parties engaged with Altus Group, including suppliers, vendors, and customers. 

d) All geographic jurisdictions where Altus Group operates have specific obligations under Australian and New Zealand legislation. 

Where Altus Group does not control operations (e.g. in joint ventures), we will take reasonable steps to influence compliance with these principles. 

3.0 Responsibilities 

The responsibility for upholding human rights and addressing modern slavery risks is shared across all levels of Altus Group. A coordinated approach involving leadership, management, employees, and external stakeholders is essential to ensure ethical practices are embedded in operations, making decisions, and engaging with suppliers and communities. 

This section outlines the specific roles and responsibilities of individuals and groups within the organisation to ensure compliance with this guideline and fulfil our legal and moral obligations. 

3.1 Board of Directors 

a) Oversight and approval of this guideline and its alignment with legal and ethical obligations. 

3.2 Corporate and Social Governance Committee 

b) Monitoring effectiveness, reviewing internal controls, and assessing risk exposure in operations and the supply chain. 

3.3 Executive and Senior Management 

a) Ensuring personnel understand and implement the guideline through training and resources. 

b) Actively encourage the reporting of any human rights or modern slavery breach. 

c) Ensuring a prompt and transparent response to any human rights or modern slavery issues reported either internally or externally. 

d) Incorporating human rights and modern slavery assessments into business decisions. 

3.4 Managers and Supervisors 

a) Promoting ethical practices and ensuring teams comply with relevant standards. 

b) Identifying and escalating potential risks or incidents. 

3.5 Employees and Contractors 

a) Understanding and adhering to this guideline and reporting concerns without fear of reprisal. 

3.6 Suppliers and Business Partners 

a) Complying with Altus Group’s Supplier Management Guideline and related policies. 

b) Demonstrating active measures to identify and mitigate modern slavery and human rights risks. 

4.0 Definitions

Human Rights 
Human rights are fundamental freedoms recognised in the UN Declaration and ILO Conventions and reflected in Australian and New Zealand law. 

Modern Slavery 
Severe forms of exploitation include slavery, servitude, forced labour, deceptive recruiting, debt bondage, child labour, forced marriage, and human trafficking. Australia defines it under the Modern Slavery Act 2018 (Cth). New Zealand addresses it under various laws (e.g., the Crimes Act 1961, the Immigration Act 2009, and the Employment Relations Act 2000), with dedicated modern slavery legislation forthcoming. 

Forced Labour 
Work performed under coercion, threat, or deception, including withheld documents or restricted movement, and is prohibited in Australia and New Zealand. 

Child Labour 
The employment of children in a manner that deprives them of their childhood, education, or is harmful to their physical and mental development. The minimum employment age in Australia is generally 15 (with state-based variations). New Zealand has no set minimum age, but specific restrictions apply to workers under 16 and 18. 

Debt Bondage 
A person is forced to work to repay a debt or other obligation, and the terms and conditions are not clearly defined or are exploitative. Prohibited under Australian law and addressed through general labour and immigration laws in New Zealand. 

Ethical Sourcing 
Ensuring that products and services are obtained responsibly and sustainably, considering human rights, fair labour, environmental impact, and anti-corruption standards throughout the supply chain. 

Freedom of Association 
The right of employees to join or form trade unions and to engage in collective bargaining is protected under the Fair Work Act 2009 (Australia) and the Employment Relations Act 2000 (New Zealand). 

United Nations Global Compact (UNGC) – Ten Principles 
A set of ten universally accepted principles covering human rights, labour, environment, and anti-corruption. They serve as a framework for responsible corporate citizenship and sustainable development, guiding businesses to align operations with universal values. 

Discrimination 
Under the Australian Human Rights Commission Act 1986 and the Human Rights Act 1993 (NZ), unfair treatment based on characteristics such as race, gender, age, religion, or disability is prohibited.