Modern Slavery Policy

Introduction 

In recent years, concerns over poor working conditions have seen companies implement specific social criteria for the sources from which they source products and services. 

This Policy is consistent with Herron Todd White’s commitment to uphold human rights and fair working conditions, and to maintaining a reputation for the highest legal, moral and ethical standards in all business transactions. It is prepared voluntarily in accordance with the requirements of the Modern Slavery Act 2018 (Cth) (The Act) on behalf of Herron Todd White (Australia) Pty Ltd (HTWA), Herron Todd White (Consolidated) Pty Ltd (HTWC), along with all franchisees of HTWC and any other entity authorised by HTWA or HTWC to provide services under the Herron Todd White brand (together referred to as Herron Todd White, we, us or our). 

Herron Todd White acknowledges that slavery involves the serious exploitation of persons, including the following matters, as defined in the Act: 

• Trafficking in person; 
• Slavery; 
• Servitude; 
• Forced marriage; 
• Forced labour; 
• Debt bondage; 
• Child labour; 
• Deceptive recruiting of labour services; and 
• The worst forms of child labour, being situations where children are subjected to slavery or similar practices, or engaged in hazardous work. 

This Policy affirms Herron Todd White’s commitment to contribute to ending all forms of modern slavery, and outlines our approach to reducing the risk of modern slavery practices within our supply chains and operations, where possible.

Structure and Operations 

Herron Todd White is one of the largest independent property valuation firms in Australia. Our vision is to be the most respected and trusted property advisory organisation. We are committed to providing solutions of superior quality and value to help our clients reach their goals. 

Herron Todd White employs over 800 employees in 62 offices located in all major metro and regional centres across Australia. Our qualified and experienced staff work in the property market every day and provide professional services for all classes of property from individual residences and major development projects, to rural and agribusiness properties and corporate and government portfolios. 

Being a values driven organisation, our values define the behaviours that guide how we interact with each other, how we make decisions and how we work together to achieve results. Those values include: 

• Collegiality – we care about building trusted relationships – with our people, our clients and our communities. 
• Professionalism – we are known for our integrity and take pride in our collective expertise. We care deeply about our brand and how we represent our communities and the broader property profession. 
• Innovation – we strive for excellence and are committed to continually improving all aspects of our work. 
• Fairness and equity – we are committed to building an inclusive culture in which every individual feels respected and valued. 
• Accountability – accountability is doing what we say we are going to do. It means taking ownership of what happens as a result of our choices, actions and behaviours. 

Our supply chains and primary procurement functions are comprised of: 

• Implementation and administration of internal practices in relation to receiving goods and services. These transactions are governed by our Ethical Sourcing Procedure and Sustainability and Ethics Policy. 
• Client engagement and management including onboarding, tenders, and compliance.
• Our supply chain includes local and international professional service providers, multinational professional services firms, and local retailers. 
• Our main supplier spend categories include IT services, local and international IT support services, software subscription services, insurance, professional consultants, and marketing services. 

The multinational and larger retailers have clear corporate responsibility policies in place that address their business practices in detail to combat modern slavery risks. 

We expect our suppliers and clients to operate in full compliance with the modern slavery laws and regulations in the jurisdiction where the goods are sourced, procured or services are performed.

Risk identification 

Through the application of Herron Todd White’s risk management framework we have implemented a range of actions to proactively identify and address modern slavery risks in our operations and supply chains, these actions include: 

• Requiring suppliers and potential suppliers to formally disclose their modern slavery risk mitigation strategies as part of our assessment processes via self-assessments and audits. 
• Investigating and reporting on identified non-conformances.

Risk management and due diligence 

To manage the risks of modern slavery in our supply chain, Herron Todd White has revised its procurement practices and undertaken the following measures: 

• Third party assessment – prior to engagement of new third party suppliers Herron Todd White will undergo a third party assessment requiring the identification of modern slavery compliance. 
• Updating our contractual terms to reflect supplier obligations to include compliance with Australian modern slavery laws and those foreign modern slavery laws that apply in location(s) in which our suppliers may operate, and to require compliance with the Herron Todd White Ethical Sourcing Procedure. 
• Encouraging our suppliers to complete a questionnaire which contains questions relevant to modern slavery. Answers to this questionnaire will provide us with a greater understanding of the risk of modern slavery within a supplier’s supply chains or operations and enable us to work with a supplier to reduce the risks identified. We will actively and progressively improve our understanding and oversight of all supply chains. 
• Revising our policies and drafting new policies, where necessary, so that we continue to reflect our commitment to combating modern slavery in all its forms.

Ongoing assessment of effectiveness of Risk Management 

Herron Todd White is committed to continuous improvement of how we reduce the risk of modern slavery practices within our supply chain. We will proactively monitor the effectiveness and compliance with current and future practices to ensure that our procurement practices do not contribute to any form of modern slavery. We will achieve this by: 

• Training our team members to increase awareness of human rights and modern slavery risks. 
• Monitoring of compliance of supplier behaviours to ensure ongoing compliance.
• Regular audits of vendor onboarding documentation, vendor database and supplier policies to ensure all potential changes that may impact Herron Todd White’s supply chain and increase our risk of contributing or causing any instances of modern slavery are discovered as early as possible.

Related Documents 

• Ethical Sourcing Procedure 
• Sustainability and Ethics Policy 

Document Control 

This Policy will be reviewed annually from the date of revision or as appropriate changes are required due to legislative or other changes impacting the arrangement.