Eliminating Modern Slavery


One of the potential major human rights risks facing 3E Group is the existence of modern slavery in the Company’s supply chain. Modern slavery has the potential to exist in the supply chain through a variety of circumstances including: 

  • Forced labour 
  • Child labour 
  • Debt bondage 
  • Human trafficking 
  • Abuse of requirements for a minimum living wage 
  • Discriminatory employment practices 

3E has committed to limiting the risk of modern slavery occurring within its own business, infiltrating its supply chains or through any other business relationship. 

3E recognises the importance of protecting human rights and is committed to protecting the rights of all people including its employees, the communities in which the Company operates, those who may be impacted by its activities, its customers, and those within its supply chains. 

3E’s supplier code of conduct, standard terms and conditions requires that minimum standards in ethical business practices, safety and environment, be met. 

While 3E has yet to formalise an Anti-Slavery Policy, our standards and practices as a Company is consistent with the principles of the Modern Slavery Act 2018 (Cth). 

3E will develop and implement a formal Anti-Slavery policy that will apply to all persons working for or on behalf of 3E, in any capacity, including employees, directors, officers, agency workers, contractors, consultants and any other third-party representative. 

To underpin our commitments, 3E aims to implement the following measures over the course of the next financial year ending June 2020: 

  1. The Company will conduct risk assessments to determine which parts of the business and which supply chains are most at risk from modern slavery so efforts can be focused on the areas that are most ‘at risk’
  2. Where appropriate, as informed by the risk assessment, the Company will engage directly with new suppliers in respect of 3E’s Anti-Slavery Policy in order to gain a proper understanding of the measures they have in place to ensure that modern slavery is not occurring within their own businesses.
  3. Our contractual documentation will incorporate specific prohibition against slavery or servitude, the use of forced, compulsory or trafficked labour, and the use of child labour in line with this policy.
  4. We will also make provision for our contracted suppliers to hold their own suppliers to the same standards. We also reserve the right to terminate any contractual arrangement if there is breach of such policy conditions.

Through contractual arrangements and procurement principles, consultants, agents, contractors and suppliers will be required to comply with the Suppliers/Subcontractors Code of Conduct. 

  Robin Archibald

Group Managing Director
3E Group
20th May 2022 


See our other Policy Statements here