Modern Slavery Policy

Welcome to our Modern Slavery Policy

1. Hi there. We're Envato and welcome to our Modern Slavery policy. This policy sets out our regard for and compliance with the Modern Slavery Act 2018 (Cth). It outlines the responsibility of Envato, its managers, employees, contractors and suppliers. It also sets out a reporting mechanism to escalate any modern slavery concerns to Envato.
2. When we say 'we', 'us' or 'Envato' we’re referring to the entire Envato Group, being Envato Pty Ltd (ABN 11 119 159 741) of Level 3, 551 Swanston Street Melbourne, 3053, Australia and its subsidiaries.
3. If we say ‘policy’ we’re talking about this Modern Slavery policy.

What is "modern slavery"?

4. Modern slavery refers to a range of prohibited activities in which coercion, threats or deception are used to exploit individuals and undermine their freedom. Collectively, these practices are referred to as "modern slavery". More specifically, these activities include slavery, servitude, forced or compulsory labour, forced marriage, debt bondage, deceptive recruiting, the worst forms of child labour and human trafficking. This policy covers all these activities.
5. We recognise that modern slavery is a serious global problem that should be eradicated. We will not tolerate the presence of modern slavery practices in our operations or supply chains.

Relevance to Envato

6. Modern slavery is a complex and multi-faceted problem and tackling it requires all of us to play a part. Modern slavery may seem irrelevant in Australia and in certain industries, but it is not. Preventing exploitation and human trafficking is a basic ethical obligation and is consistent with Envato’s values. The Modern Slavery Act recognises the important role businesses can and should play in tackling modern slavery and encourages them to do more.
7. With this in mind, Envato needs to pay particularly close attention to:
   1. our structure;
   2. our operations;
   3. our supply chains (including our sub-contractors, direct (i.e. tier 1) suppliers, their suppliers and sub-contractors and so on down those supply chains to the source of raw ingredients and other products, no matter their place of origin).

Responsibilities

8. Envato, its managers, employees, contractors and suppliers have responsibilities to ensure workers in our operations and supply chains are safeguarded and treated lawfully, fairly and with dignity. Everyone must observe this policy and be aware that turning a blind eye to modern slavery practices (or the risk of those practices) is not acceptable and is not an option.
9. We will:
   1. maintain clear policies and procedures preventing modern slavery and protecting the workers in our operations and supply chains;
   2. be clear about our recruitment policy (see below regarding Recruitment);
   3. lead by example by making appropriate checks on all employees, recruitment agencies, suppliers, etc. to ensure we know who is working in our operations and supply chains;
   4. ensure we have in place an open and transparent grievance process for all workers in our operations and supply chains;
   5. seek to raise awareness so that all workers in our operations and supply chains know what we are doing to promote their welfare;
   6. make clear statements to regulators, customers and suppliers that we take our responsibilities to all workers in our operations and supply chains seriously.
10. Managers will:
    1. listen and be approachable to workers in our operations and supply chains;
    2. respond appropriately if they are told something that might indicate a worker is in an exploitative situation;
    3. remain alert to indicators of modern slavery (see below regarding Identifying Modern Slavery);
    4. raise the awareness of our employees, contractors, sub-contractors and suppliers, by discussing modern slavery and providing training, so that everyone can spot the signs of modern slavery and know what to do about it;
    5. use their experience and professional judgement to gauge situations.
11. Envato, its managers, employees, contractors and suppliers all have responsibilities under this policy. Whatever your role or level of seniority, you must:
    1. keep your eyes and ears open—if you suspect someone in our operations or supply chains is being controlled or forced by someone else to work or provide services, follow our reporting procedure (see below regarding Reporting Modern Slavery);
    2. follow our reporting procedure (see below) if a worker tells you something you think might indicate they are or someone else is being exploited or ill-treated;
    3. tell us if you think there is more we can do to prevent people from being exploited.
12. During the procurement process, we will engage with our high spend and medium-high risk suppliers to seek to ensure that they are addressing modern slavery issues in their businesses.

Anti-slavery statements

13. We will make clear annual statements to demonstrate that we take our responsibilities to our employees and people working within our operations and supply chains seriously. We will submit these statements to the appropriate regulatory authorities in compliance with our obligations under the Modern Slavery Act.

Recruitment

14. Envato's Talent Team will follow this policy and only use agreed specified reputable recruitment agencies.

Recruitment of employees

15. We will ensure that employees have a written contract of employment and that they have not had to pay any direct or indirect fees to obtain work with Envato.
16. We will ensure that employees are legally able to work.
17. We will provide information to all new employee recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to.
18. If, through our recruitment process, we suspect an employee is being exploited, the People Team will follow our reporting procedures (see below regarding Reporting Modern Slavery).

Recruitment of contractors

19. We will ensure that contractors have a written services agreement.
20. We will check that contractors are legally able to work (for example are of legal working age in their country, or in the absence of any applicable legal age in accordance with the International Labour Organisation Convention 138).
21. If we suspect a contractor is being exploited our reporting procedure will be followed by the relevant recruitment team (see below Reporting Modern Slavery).

Identifying modern slavery

22. There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support.
23. However, the following key signs (which are not exhaustive in nature) could indicate that someone may be a modern slavery victim. The person:
    1. is not in possession of their own passport, identification or travel documents;
    2. is acting as though they are being instructed or coached by someone else;
    3. allows others to speak for them when spoken to directly;
    4. is dropped off and collected from work;
    5. is withdrawn or appears frightened;
    6. does not seem to be able to contact friends or family freely;
    7. has limited social interaction or contact with people outside their immediate environment.
24. Remember, a person may display a number of the indicators set out above, but they may not necessarily be a victim of modern slavery. Often you will build up a picture of the person’s circumstances which may indicate something is not quite right.
25. If you have a suspicion, report it.

Reporting modern slavery

26. Talking to someone about your concerns may stop someone else from being exploited or abused.
27. If you think that someone is in immediate danger:
    1. in Australia, dial 000 to contact the police or call local police;
    2. in the US, dial 911 to contact the police or call local police;
    3. in Mexico, dial 911 to contact the police or call local police;
    4. in New Zealand, dial 111 to contact the police or call local police; or
    5. call the phone number for police in the relevant location.
28. Otherwise, you should discuss your concerns with Envato’s General Counsel ([email protected]) who will decide a course of action and provide further advice.
29. Not all victims may want to be helped and there may be instances where reporting a suspected modern slavery case put the potential victim at risk, so it is important that in the absence of an immediate danger, you discuss your concerns first with Envato’s General Counsel before taking any further action.

Review and Training

30. We will regularly review this Modern Slavery policy and may amend it from time to time.
31. Envato will provide training to its managers and individuals dealing with contracting and maintaining relationships with suppliers. We will also make relevant information available to our staff on our intranet.