Modern Slvavery Statement

Compliant in accordance with the Modern Slavery Act 2018 (Cth)

Colorful paper figures holding hands

Introduction

ACNS is committed to conducting business ethically and responsibly. We recognise the serious
human rights impacts associated with modern slavery and maintain a zero tolerance approach
to any form of forced labour, human trafficking, exploitation or unethical employment practices

Our Operations and Supply Chains

As a provider of workforce services to aged care providers and community organisations, ACNS recognises the importance of protecting workers and ensuring fair and lawful employment
practices across all areas of our operations.

Our core activities in operations include:

Recruitment and credentialing of healthcare professionals
Workforce placement and shift coordination
Payroll and contractor management
Compliance monitoring (AHPRA registration, working rights, background checks)

Our supply chains include:

Recruitment and labour hire networks
Payroll and HR systems providers
IT and cloud service providers
Uniform and medical equipment suppliers
Office equipment and facilities management
Professional advisers (legal, accounting, compliance)

While our primary workforce is Australia-based and regulated, we acknowledge that risks may exist within indirect supply chains such as uniform manufacturing, technology hardware production, and outsourced service providers.

Modern Slavery Risks in Aged Care Staffing

Modern slavery includes serious forms of exploitation such as forced labour, debt bondage, servitude, human trafficking, and deceptive recruitment practices. 

In the aged care staffing sector, potential risk areas include:

Exploitation of Migrant Workers

Recruitment fees charged by third parties
Visa-related coercion
Underpayment or unlawful deductions
Threats relating to sponsorship arrangements

Labour Hire Vulnerabilities

Misclassification of employment arrangements
Excessive working hours
Inadequate oversight of subcontracted recruitment agents

Indirect Supply Chain Risks

Offshore uniform manufacturing
IT hardware production
Medical supply chains in higher-risk jurisdictions

Although Australia is considered a lower-risk jurisdiction due to strong regulatory frameworks, including Fair Work and AHPRA requirements, we recognise that vulnerabilities still exist, particularly affecting migrant workers and temporary visa holders.

Actions Taken to Address Modern Slavery Risks

ACNS works to reduce the risk of modern slavery by implementing responsible employment and
recruitment practices, including:

Ethical Recruitment Practices

Direct recruitment wherever possible
Prohibition on charging recruitment fees to candidates
Clear written employment contracts outlining wages and conditions
Transparent pay structures aligned with applicable awards
Verification of visa status and working rights

Workforce Compliance Controls

National Police Checks
NDIS Worker Screening (where applicable)
Monitoring of hours worked to prevent excessive scheduling
Payroll audits to ensure compliance with award rates

Supplier Due Diligence

Review of key suppliers’ labour standards
Preference for Australian-based suppliers where possible
Inclusion of contractual clauses requiring compliance with labour and anti-slavery laws
Assessment of suppliers’ Modern Slavery Statements (where applicable)

Policies and Governance

We maintain internal policies supporting ethical labour practices, including:

Whistleblower Policy
Equal Opportunity and Anti-Discrimination Policy
Workplace Health and Safety Policy
Code of Conduct
Workplace Behaviour Policy

Training and Awareness

We provide internal training to management and recruitment teams covering:

Ethical hiring practices
Identification of exploitation indicators
Reporting obligations

Assessing Effectiveness

To assess the effectiveness of our actions, we:

Review recruitment and payroll compliance processes
Monitor supplier performance
Conduct periodic internal audits
Review complaints and incident reports
Update risk assessments annually