Modern Slavery and Ethical Supply Chains

fr&nk Capability Leaders is committed to identifying, assessing, and addressing modern slavery risks within our operations and supply chain. We recognise that modern slavery can occur across many industries and regions and that organisations have a responsibility to take reasonable steps to prevent, identify, mitigate, and remedy these risks.

Our approach is proportionate to the size, nature, and risk profile of our business and is informed by guidance issued by the NSW Anti-slavery Commissioner, including its guidance on reasonable steps.

Our Commitment

We are committed to conducting our business ethically, transparently, and in a way that respects human rights. This includes taking active steps to ensure our services are delivered in a manner that does not contribute to modern slavery practices and working with suppliers who share these values.

Identifying and Assessing Risk

We take a risk-based approach to identifying potential modern slavery risks within our operations and supply chain. This includes:

  • Understanding the nature of our services and how they are delivered

  • Considering modern slavery risk factors associated with industries, geographies, and labour practices

  • Assessing supplier arrangements, particularly where goods or services are sourced through third parties

  • Reviewing procurement and engagement practices to identify areas of elevated risk

Given the professional services nature of our work, our direct risk exposure is assessed as low. However, we recognise that risks may still exist within broader supply chains and take steps to remain alert to these risks.

Reasonable Steps in Practice

In line with the NSW Anti-slavery Commissioner’s guidance, we take the following reasonable steps to prevent, identify, and address modern slavery:

  • Ethical procurement practices
    We engage suppliers and partners who demonstrate lawful, ethical, and responsible business practices. Where appropriate, we seek assurance that suppliers comply with applicable workplace, labour, and human rights laws.

  • Supplier awareness and expectations
    We communicate our expectations around ethical conduct and modern slavery to suppliers and reserve the right to review or cease engagements where serious concerns arise.

  • Policies and governance
    Our broader governance framework, including codes of conduct and procurement controls, supports ethical decision-making and responsible supply chain management.

  • Ongoing vigilance
    We periodically review our operations and supplier relationships to ensure our approach remains appropriate and proportionate to our risk profile.

Addressing and Remediating Issues

If potential modern slavery concerns are identified, we are committed to responding in a considered and responsible way. This may include:

  • Raising concerns with suppliers or partners and seeking corrective action

  • Escalating matters where necessary and disengaging from suppliers who fail to address serious issues

  • Supporting lawful and appropriate remediation pathways where harm is identified

Continuous Improvement

We recognise that addressing modern slavery is an ongoing responsibility. We continue to refine our approach by:

  • Monitoring developments in legislation and regulatory guidance

  • Learning from sector guidance and better practice examples

  • Reviewing and strengthening our processes as our business and supply chain evolve

Through these actions, fr&nk Capability Leaders demonstrates its commitment to taking reasonable and meaningful steps to address modern slavery risks and to comply with applicable Modern Slavery Laws.