Modern Slavery Transparency Policy Statement
Infomedia Ltd (Infomedia Group (including all wholly owned subsidiaries), Infomedia or the Company) is committed to acting ethically and with integrity in all business relationships and maintaining and improving systems and processes to avoid complicity in human rights violations within our own operations and within our direct supply chain.
At Infomedia we acknowledge our role in seeking to safeguard human rights through ethical and sustainable business practices. We also recognise the growing importance of human rights issues to our key stakeholders including our employees, shareholders and our customers.
This statement is made voluntarily in relation to the Infomedia Group and is based on the approach expressed in s54 of the United Kingdom’s Modern Slavery Act 2015 (UK), however, Infomedia is not amenable to those provisions. This statement uses the United Kingdom government’s definition of ‘modern slavery’ which includes slavery, human trafficking and forced labour.
The Company also acknowledges the recent passing of the Modern Slavery Act 2018 (NSW) which will make reporting of this nature mandatory in future periods. The Company is monitoring the development of associated regulations and reporting obligations and will re-assess its approach to modern slavery reporting based on these outcomes.
Infomedia is a leading global provider of Software as a Service (SaaS) solutions to the parts and service sector of the global automotive industry. Founded in 1987, Infomedia supplies online parts selling systems, sophisticated service selling systems and data analysis and information research for the automotive and lubricant industries.
Our core business objective is to make our customers successful. We empower our automotive partners by providing highly available, effective and innovative SaaS tools and information solutions which advance their productivity, efficiency and profitability whilst simultaneously enhancing the, service experience of their customers.
We create value for our customers by following our Core Values:
- Accelerating Performance – We are accountable to our stakeholders and action orientated.
- Driving Innovation & Service – We aim to be cutting edge, always first and continuously seeking to evolve. Our technology leadership empowers our customers.
- Navigating Global, Steering Local – We are ‘One Infomedia’ and we all share the same vision. We have a unified customer approach with local execution. Customer centricity is the key to our success.
- Having Fun in the Fast Lane – We balance hard work with a fun and vibrant workplace that encourages creativity and expression. Our culture is open and welcoming. We encourage our people to flourish as professionals at work and as individuals outside of work. not clear why this reference is here
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Our supply chain
Infomedia is committed to ensuring modern slavery does not exist within our supply chain and that the human rights of workers are upheld. Infomedia has a procurement function in Australia. Given the nature of our business, our supply chain mostly consists of the hiring of service providers and the procurement of software-related goods and services.
We source goods and services from reputable suppliers and the nature of the goods and services do not generally require the types of labour at risk of modern slavery.
We recognise that some of our suppliers are in geographical regions prone to a higher risk of modern slavery. We will not support a supply chain where we are aware of, or have reasonable grounds to believe that, modern slavery is taking place and would not enter into any new agreement, or would terminate an existing supply contract in these circumstances.
Policies & governance approach
Our Code of Conduct (Code) outlines the standard of conduct expected of all directors, officers, employees and contractors of the Infomedia Group, and provides guidance to ensure that proper ethical and legal decisions are made when conducting business for us and performing day-to-day duties. The code aligns with the Core Values and includes reporting procedures and accountability provisions.
In the event of violation of the Code, disciplinary actions may include immediate termination of employment or the business relationship. A summary of our Code is available here.
Through this Code, our company values and the full range of our other internal policies maintained by the Company, we seek to promote honest and ethical conduct, deter wrongdoing and support compliance with applicable laws and regulations in every aspect of our business.
Our Whistleblower Policy sets an effective framework for the reporting and investigation of misconduct for employees to report concerns within our business or supply chain, without fear of reprisal. A summary of our Whistleblower Policy is available here.
Risk based approach
We maintain an active risk management program aligned to ISO 31000 standards, to identify, assess, monitor and manage perceived business risks. Risk assessment extends to supply chain risk, including risk of modern slavery. The Company identifies risk in its supply chain based on numerous factors including the geographic location of the supplier, the nature of the goods or services supplied and our relationship with the supplier generally. We intend to further develop and standardise our risk based approach to supplier selection and review during the FY19 financial year.
The Company applies a due diligence process to suppliers that pose an elevated risk, as identified in the risk management phase. Supplier agreements are implemented with safeguards deemed appropriate to the level of risk presented. In addition to contractual provisions, the Company has sought appropriate assurances from suppliers with elevated risk profiles, and has in some instances conducted on site visits to suppliers located in developing nations.
Futher steps to prevent modern slavery
As part of our continuous commitment to improvement, Infomedia will take steps to develop procedures, requirements [and educate our employees] to address issues of modern slavery. Infomedia will continue to examine its due diligence processes and evolve our supply chain during the FY19 fiscal year to ensure that our suppliers are compliant with our policies and requirements.
This statement was approved by our Board of Directors on 30 July 2018 and signed on its behalf by Jonathan Rubinzstein.
Chief Executive Officer and Managing Director