HUMAN RIGHTS and MODERN SLAVERY GUIDELINE

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 

a) 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. 

5.0 Procedure 

Altus Group integrates the Ten Principles of the UN Global Compact into our daily operations, procedures, and business relationships. These principles provide a practical foundation for promoting and embedding respect for human rights, fair labour standards, environmental responsibility, and anti-corruption across our operations and supply chains. 

5.1 Promoting Human Rights in the Workplace 

Altus Group is committed to maintaining a workplace environment that respects all individuals' dignity, equality, and rights. Our internal guidelines and policies reflect this commitment, ensuring all employees are treated fairly and equitably regardless of their background. 

We actively prohibit all forms of discrimination, harassment, and abuse. Employees are selected, promoted, and developed based on merit, performance, qualifications, and experience, regardless of race, gender, age, religion, disability, sexual orientation, national origin, or other protected status. 

These efforts are aligned with the UNGPs and our commitment to provide remedies in cases of identified human rights violations. 

To support a safe working environment, we uphold robust health and safety standards and enforce a zero-tolerance approach to workplace violence or threats. Employees are encouraged to raise concerns or report violations through designated internal reporting channels without fear of reprisal. 

Altus Group recognises workers' rights to freedom of association and collective bargaining. We maintain open lines of communication with staff to foster a culture of collaboration, inclusion, and continuous improvement. 

5.2 Upholding Ethical Supply Chains 

Our ethical obligations extend beyond our direct operations and into our supply and value chains. Altus Group expects suppliers to comply with legal and ethical labour practices. These expectations are communicated through supplier onboarding processes and reinforced through contractual obligations, including adherence to our Supplier Management Guideline. 

Before entering any commercial relationship, we assess supplier practices based on geography, industry, and previous performance. Where risks are identified, we may implement mitigation measures such as deeper audits, third-party reviews, or required corrective actions. 

5.2.1 Summary of Supplier Requirements Requirement 

Child Labour 
Prohibited; minimum age of 15 unless local law dictates otherwise. 

Forced Labour 
Not permitted; workers must be free to leave and retain identification. 

Discrimination 
Prohibited based on race, gender, religion, disability, or other status. 

Wages and Benefits 
Must meet or exceed legal minimum standards and be paid promptly. 

Working Conditions 
Must comply with laws; excessive hours prohibited. 

Freedom of Association and Collective Bargaining 
Must be respected and not restricted. 

Health and Safety 
Workplaces must be safe and compliant with all legal standards. 

Disciplinary Practices 
No coercion, violence, or punishment; policies must be transparent and fair. 

Non-compliance with these requirements is considered a material breach and may result in suspension or termination of the supplier relationship. 

5.2.2 Alignment with the UN Global Compact Principles 

Altus Group applies the UN Global Compact’s Ten Principles to support ethical, sustainable, and transparent business practices. The table below outlines how these principles are reflected in our procedures. 

5.3 Risk Identification and Due Diligence 

Altus Group integrates human rights and modern slavery risk assessments into procurement, investment, and operational decisions. Due diligence processes may include mapping supply chains, identifying high-risk regions or sectors, and evaluating suppliers’ practices through questionnaires, audits, or third-party certifications. 

Our risk-based approach ensures that we allocate resources to monitor areas with the highest potential for exploitation or unethical behaviour. For example, construction, textiles, electronics, and low-wage manufacturing procurement will typically require enhanced scrutiny. 

Where risk is identified, we will either work with the supplier to implement improvements or, where necessary, reconsider the commercial relationship. 

All findings and risk assessments will be documented and retained to meet the reporting and recordkeeping requirements of the Modern Slavery Act 2018 (Cth) and New Zealand’s forthcoming legislation. 

5.4 Training and Awareness 

Altus Group provides targeted training to personnel in roles where they may be exposed to modern slavery risks, such as procurement, recruitment, site operations, or fieldwork in high-risk regions. 

Training covers: 

a) The principles of human rights and modern slavery. 
b) How to identify red flags in supply chains or business operations. 
c) Responsibilities under Australian and New Zealand legislation. 
d) How to respond to and escalate concerns appropriately. 

Training is delivered on a recurring basis and updated as needed to reflect emerging risks, legal developments, and internal learnings. 

5.4.1 Examples of Red Flags for Modern Slavery 

5.5 Reporting and Grievance Mechanisms 

Altus Group encourages all personnel and stakeholders to report concerns regarding human rights or modern slavery through confidential internal reporting channels or via our Speak Up and Whistleblower program. All reports shall be treated seriously and confidentially, and whistleblowers are protected from retaliation. 

Reports may be made to: 

a) Supervisors or Managers. 
b) The People team. 
c) Anonymously through designated whistleblower hotlines. 
d) External authorities, where appropriate. 

Each report is investigated promptly, with outcomes recorded and remediation steps implemented where necessary. Suppliers are also expected to report any breach or suspected breach of relevant laws or our Code of Conduct. 

Where modern slavery or human rights breaches are identified, Altus Group will work with affected individuals and relevant authorities to provide appropriate remediation and ensure non-recurrence. 

5.6 Monitoring and Continuous Improvement 

Altus Group regularly reviews its human rights and modern slavery procedures to ensure their ongoing effectiveness. Key activities include: 

a) Internal audits of procurement and contracting practices. 
b) Supplier performance reviews. 
c) Engagement with industry groups and third-party experts. 
d) Updates to this guideline in response to regulatory change or audit findings. 

In line with the Modern Slavery Act 2018 (Cth), Altus Group maintains records of risk assessments, supplier reviews, mitigation actions, and statement approvals to ensure transparency and compliance. 

Altus Group will also prepare to meet New Zealand’s proposed modern slavery disclosure obligations and comply with the NSW Modern Slavery Act 2018 if and when enforcement provisions are formally enacted. 

6.0 References 

6.1 Australia 

a) Modern Slavery Act 2018 (Cth). 
b) Fair Work Act 2009 (Cth). 
c) Work Health and Safety Act 2011 (Cth and States/Territories). 
d) Australian Human Rights Commission Act 1986 (Cth). 
e) Privacy Act 1988 (Cth). 
f) Anti-Discrimination Acts (relevant State/Territory-based). 
g) Modern Slavery Act 2018 (NSW) – if enacted/enforced. 

6.2 New Zealand 

a) Employment Relations Act 2000. 
b) Crimes Act 1961. 
c) Immigration Act 2009. 
d) Health and Safety at Work Act 2015. 
e) Human Rights Act 1993. 
f) Privacy Act 2020. 
g) Minimum Wage Act 1983. 
h) Equal Pay Act 1972. 
i) Modern Slavery and Worker Exploitation legislation (forthcoming). 

6.3 International Framework - UN Global Compact 

a) United Nations Global Compact - Ten Principles 
b) United Nations Guiding Principles on Business and Human Rights (UNGPs) 

7.0 Related Documents 

a) AST 11.08.02 - Supplier Management Guideline. 
b) PPL 09.01.01 - People Policy. 
c) PPL 09.03.01 - Recruitment and Retention Guideline. 
d) PPL 09.04.01 - Code of Conduct Policy. 
e) PPL 09.04.02 - Equal Employment Opportunity, Anti-Discrimination and Harassment Policy. 
f) PPL 09.06.01 - Training, Learning and Competency Guideline. 
g) PPL 09.08.01 - Grievance and Dispute Resolution Policy. 
h) PPL 09.08.02 - Grievance and Dispute Resolution Guideline. 
i) RSK 03.04.01 - Speak Up and Whistleblower Policy. 
j) RSK 03.04.02 - Speak Up and Whistleblowing Guideline.