Techtronic mentions some policies that it has developed on page 8. These are a Conflict Minerals Policy, Policy against Modern Slavery and Human Trafficking and a Cobalt Procurement policy, however all policies are high level and do not make any specific commitments regarding concrete actions to combat slavery in tier 1 or beyond.
Page 6:
"This year TTI has reengaged all indirect vendors and gained agreement to follow TTl's established Policies. TTI will renew the agreement to Policies in line with contract renewal terms.
Our Policy Against Modern Slavery and Human Trafficking outlines the various steps taken by
TTI to verify, investigate, audit and remedy as follows:
- Training and acknowledgement on the Business Partner Code of Conduct for and by suppliers;
- Human trafficking and modern slavery provisions included in key supplier contracts;
- Acknowledgment on Policy Against Modern Slavery and Human Trafficking by our
employees and suppliers;
TTI requires each Supplier or Vendor to make a declaration regarding their compliance
with our Ethical Sourcing Policy."
The relevant policies are listed on page 8:
"TTI has developed and implemented policies and practices that describe its approach to human
rights and, in particular, to the prevention of modern slavery and human trafficking in its
operations and supply chain. These policies are published on our parent company's website:
Employee Code of Ethics & Business Conduct: The code makes it clear to employees
what are the actions and the ethica l behaviour expected.
• Business Partner Code of Conduct: The code sets out TTI requirements and
expectations and requests all suppliers to acknowledge the code.
• Conflict Minerals Policy: This policy sets up the ru les, standards and expectations that
TTI and its suppliers must abide by to ensure that TTI and its suppliers must source four
materials - Tin, Tungsten, Tantalum, and Gold ("3TG") from reputable sources free from
confl ict or other human rights violations.
• Policy Against Modern Slavery and Human Trafficking: This policy sets furt her
expectations in relation to human rights and modern slavery and provides a list of
potential red flags as guidance to assist employees in identifying and rectifying t he issues
at an early stage.
• Cobalt Procurement Policy: This pol icy sets up the rules, standards and expectations
that TTI and its suppliers must abide by to ensure t hat TTI and its suppliers must source
cobalt from reputable sources free from human rights violations."
"TTI will establish its Ethical Supply Chain Steering Committee in Australia & New Zealand in the near future. For 2022, the business has relied on existing robust policies and procedures within its operations and supply chain to conduct due diligence, gain agreement of Supplier Code of Conduct and Modern Slavery Policy from a majority of indirect vendors and support compliance standards.
Despite this delay, TTI remains committed to, and has commenced planning and resourcing, based on the preliminary scoping exercise, and has committed to commencing the steering committee in the next reporting period, and to implementing meaningful and robust actions to reduce risk and practices of modern slavery within our operations and supply chains." (Page 5).