Modern Slavery Policy

About Us

Homecorp Constructions Pty Ltd and its wholly owned subsidiaries (“the Group” or “Group”) are a reporting entity under the Modern Slavery Act 2018 (C’th) (“the Act”). Homecorp Constructions Pty Ltd is a company incorporated in Australia. This is a joint report of Homecorp Constructions Pty Ltd and its subsidiaries which operate with a centralised management structure.

Structure, Operations and Supply Chains

The Group operates a construction and property development business across Queensland, New South Wales, and South Australia through its parent company and incorporated subsidiaries, per the group structure diagram on the previous page.

The Group’s products comprise of:
• Detached dwellings
• Medium-density integrated housing developments
• Land subdivision

The Group’s in-house operations are conducted by approximately 100 employees and include:
• Land acquisition
• Dwelling design
• Project management
• Housing construction, and
• Sales and marketing

Housing construction is delivered through a core team of Group employees in each state using subcontractors for the housing construction. Other in-house operations are coordinated by employees using a combination of internal resources and external consultants.

The supply chains of the Group’s operations include professional consultants, on site labour, and building material suppliers.

The Group’s supply chain includes the manufacturers of construction materials, building material suppliers, on-site labour, transport services, and wholesalers. Additionally, the administrative operations of the business are supported by services provided to the offices of the Group, including cleaning, security, office supplies and other such goods and services.

Risks of Modern Slavery Practices in our Operations and Supply Chain

The Group operates solely in Australia where the culture, laws and standards of our society support the rights and freedom of the individuals within our community. Even in this environment, the Group recognises that the risk of modern slavery and exploitation does exist within Australia.

The Group has no tolerance for practices that do not respect the rights of individuals. The Group’s approach to the risk assessments and practices described within this report reflects this overall level of risk.

The areas of the Group which are assessed to have a higher risk of modern slavery practices are limited to where our operations may be connected to modern slavery through the activities of suppliers of goods and labour we have a business relationship with. This includes the risk of work being undertaken by unskilled labour of the contractor/supplier (such as on-site labour or cleaners), or materials from its suppliers that are imported from countries where modern slavery practices might exist.

Actions Taken to Address the Risk of Modern Slavery Occuring

• A comprehensive employee handbook made available to all staff on the Group’s intranet, which includes the Group’s code of conduct, policies on modern slavery tolerance and reporting, harassment, bullying and discrimination, and workplace health and safety. This serves to set the tone for how the business is conducted.

• A whistle-blower policy available to all staff describing the protected disclosures staff can make; how they can make such disclosures; and how the Group will respond. This reinforces the Group’s culture to staff.

•The development of long-standing relationships with reputable suppliers to allow the Group to have a greater understanding of the culture and practices of our suppliers to better understand where the risk of modern slavery practices may exist.

• Internal processes for assessing the remuneration of new employees against legal entitlements to ensure new staff are not paid below that to which they are entitled to.

• A full salary audit is performed each year in relation to salaries and all new employees are checked against the Fair Work pay calculator to ensure they are paid above the award.

• Using labour hire firms with modern slavery policies and practices.

• Ceasing relationships with any suppliers where modern slavery practices are indicated or have been identified.

Assessment of Effectiveness of Actions

The effectiveness of these practices and actions are evaluated on a continual basis with the Group responding where evidence is found that the Group or its suppliers exhibit practices which are inconsistent with the Group’s approach to addressing the risk of modern slavery. Evidence brought to our attention by staff, media reports, regulatory agencies or law enforcement must be recorded in a dedicated incident report register. The register includes the following information:

• date reported
• how incident report was received
• nature of matter
•the status of the matter, and
• who is responsible for investigation and developing responses to the specific matter and developing policy responses.

Any matters identified are then to be appropriately investigated, reported and actions designed to resolve identified instances of modern slavery practices, and develop policy responses to prevent reoccurrence.

Process of Consultation with any Entities the Group Owns or Controls

The Group has a centralised management and operational structure which applies to all entities within the scope of this statement. The centralised structure is reflected in all aspects of the Group, including centralised procurement, human resource practices, management decision making, treasury function, policies and procedures.

It is on this basis that consultation with any entities that the reporting entity owns or controls and the entity giving the statement inherently occurs. This statement was prepared through dialogue with the company secretary, the board of directors, the executive management team and the finance team.