Introduction

This statement sets out Sanctuary Recruitment’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1st July 2023 to 30th June 2024.

As part of the healthcare sector and recruitment industry, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking. Our organisation is committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational Structure and Supply Chains

This statement covers the activities of Sanctuary Recruitment:

With over 8 years of experience in the healthcare market, Sanctuary Recruitment has built an excellent reputation as a market leader for recruiting and supplying highly skilled specialist candidates throughout Australia. Sanctuary Recruitment grow and diversify the market we serve by recruiting and retaining the best people, empowering them with innovative technology solutions. Our aim is to be the first-choice partner for aged care professionals and providers across Australia. Our solutions are delivered through three segments: specialised staffing, workforce management solutions, and health and aged care services.

In line with Sanctuary Recruitments' values of Personal Leadership, Respect, Integrity, Accountability, and Transparency, as well as being a leading partner in the healthcare sector and recruitment industry, we recognise that we have a strong responsibility to take a robust approach to slavery and human trafficking. We will not tolerate slavery and human trafficking in our business or supply chain. We are committed to acting ethically and with integrity in all our business dealings and relationships to implement and enforce effective systems and controls to ensure that any form of slavery is not taking place in our own business or supply chains. Whilst we assess the risk of modern slavery as low in our supply chain, we have taken appropriate steps to ensure our procedures are appropriate by:

• Ensuring robust recruitment procedures which include immigration checks.
• Ensuring employees and temporary workers have the correct right-to-work status and documents.
• Confirm that appropriate clearing is obtained (e.g. NDISWC, AHPRA).
• Ensuring employees and temporary workers are appropriately trained.
• Strong policies and procedures for the business overall are in place.

Our business and livelihood depend upon our customers. Every employee is responsible for ensuring that any contact with our customers and the public at large reflects professionalism, efficiency, and honesty. We constantly strive to provide a ‘Best Value’ high-quality service:

• We shall uphold the values of honesty, partnership, and fairness in our relationships with stakeholders.
• We shall ensure a high level of business performance while minimising and effectively managing risk.
• We shall strive to provide continuous improvement in terms of service quality and cost.
• We will register and resolve customer complaints in accordance with our standards of service.
• We will deal fairly with temporary workers and suppliers in our supply chain.
• We will not create barriers to the use of small and medium-sized enterprises that are qualified to provide goods or services, and we will encourage innovation in our supply chains to increase the value or quality of supply.
• We will be fair and reasonable in our payment practices.

Responsibility

Responsibility for our anti-slavery initiatives is as follows:

Policies: The Directors are responsible for the policy management, control, and administration of the policy development process which includes maintaining a central register of all policies, ensuring policies are reviewed in a timely manner, ensuring consistency through the policy development process, archiving superseded policies onto Sanctuary Recruitment Pages and removing superseded policies.

Investigations/due diligence: Sanctuary Recruitment adopts a transparent approach to the recruitment and placement of our candidates and employees, and fully complies with the Duty of Candour principles, and the Modern Slavery Act 2015. Sanctuary Recruitment has robust contracts and/or service-level agreements with all supply chains which promote transparency between both parties. Any incidents of modern slavery and/or human trafficking are documented, investigated (if appropriate), and referred appropriately to the regulatory bodies in accordance with the Sanctuary Recruitment Incidents Policy/Procedure and in line with the Modern Slavery Act 2015.

Whistleblowing: Sanctuary Recruitment has an internal feedback and concerns system that employees can access if they suspect modern slavery is taking place.

Training: Sanctuary Recruitment employees complete a modern slavery training module. Refresher training will be applicable for all Sanctuary Recruitment employees regularly thereafter.
Relevant Policies

Modern slavery, human trafficking, and other forms of exploitation are included in the Acacium Group Safeguarding Adults and Acacium Group Safeguarding Vulnerable Children Policies. These policies include warning signs and reporting/escalation processes. Other policies and procedures that further support the identification and management of Modern Slavery and Human Trafficking are:

• CORP 03 - Whistleblowing for Internal Employees Policy
• CORP 04 - Whistleblowing for Associate Workers and External Partners Policy
• CORP 07 - Equality, Diversity, and Inclusion Rights Policy
• CORP 08 - Corporate Responsibility Policy
• CORP 14 - Complaints Policy
• CLIN 08 - Safeguarding Children Policy
• CLIN 09 - Safeguarding Vulnerable Adults Policy
• ORG 13-2 - Recruitment and Selection Policy

Performance indicators

We have reviewed our key performance indicators, and as a result, we are:

• Continuing to review our policies and procedures to ensure that any form of slavery is not happening in our own business or supply chains.
• Ensuring robust recruitment procedures which include immigration checks are in place.
• Ensuring employees and temporary workers have the correct right-to-work status and documents.
• Confirming that appropriate clearing is obtained (e.g. NDISWC, AHPRA).
• Ensuring employees and Temporary Workers are appropriately trained.
• Requiring all Sanctuary Recruitment employees to complete modern slavery training.