Modern Slavery Statement
Introduction
This Modern Slavery Statement is made by the MyEmpire Group of companies pursuant to the requirements of section 54(1) of the U.K. Modern Slavery Act 2015 and Part 2 of the Australian Modern Slavery Act 2018 (collectively, the ‘Acts’).
For the purposes of Part 2 of the Australian Modern Slavery Act 2018, this statement is made on behalf of MyEmpire Group Pty Ltd (ABN 36 133 227 906).
For the purposes of Chapter 30, Part 6, Provision 54 of the U.K. Modern Slavery Act 2015, this statement is made on behalf of MyEmpire Group Ltd (14391538).
MyEmpire is committed to operating in an ethical and legally compliant manner under the Acts, and we encourage our suppliers to share these values. As part of this commitment, we strongly oppose all forms of modern slavery and are committed to taking appropriate steps to minimise the risk of modern slavery occurring in our operations and supply chains.
Purpose
The purpose of this statement is to:
- Outline MyEmpire’s approach to ensuring our business and supply chains are conducted within a framework that mitigates modern slavery risk
- Set out the responsibilities of MyEmpire, its employees, contractors, suppliers, and business partners in observing and upholding MyEmpire’s position on modern slavery, including in compliance with the Acts.
Structure, Operations and Supply Chains
Organisational Structure
MyEmpire Group is a cyber security professional services organisation operating in Australia and the United Kingdom, attaining the highest level of industry standard security practices, including ISO 27001:2022, Essential Eight, Cyber Essentials and Cyber Assurance (Level 1).
MyEmpire is headquartered in Melbourne, Australia, and is comprised of two corporate entities across Australia and the United Kingdom. MyEmpire has a defined Organisational Chart for its resources and business operating model.
Operations
MyEmpire provides cyber security related professional services to public and private sector organisations. MyEmpire’s operations are delivered by its employees in Australia and the United Kingdom. It is MyEmpire’s preference to engage persons as employees rather than contractors where possible.
MyEmpire’s primary service offerings include, but are not limited to:
- Strategy and consulting
- Security and assurance testing
- Governance, Risk & Compliance (GRC) consulting
- Cyber education and training
- Security tool implementation and management
- vCISO.
Key supply chains areas
MyEmpire’s supply chain is comprised of goods and services that support the cyber security consultancy services across Australia and the United Kingdom. As MyEmpire is solely focused on providing professional services for its customers, MyEmpire has a limited supply chain when assessing modern slavery risks.
Through review, MyEmpire confirmed that the supply chain is predominantly centred around providing goods and services to enable the delivery of services in the following key categories:
- Technology and hardware
- Professional services
- Staff apparel and merchandise
- Travel (limited).
Most of the goods and services procured come from Australian based suppliers, however, MyEmpire also recognises that some companies in the supply-chain source goods or services from outside Australia, including some jurisdictions that present a higher risk of modern slavery. These include:
- IT hardware – including laptops, docking stations and peripherals – which is produced in China
- MyEmpire merchandise that is procured from local suppliers is occasionally sourced goods from China.
Risks of Modern Slavery Practises in MyEmpire’s Operations and Supply Chains
The Australian Modern Slavery Act 2018 defines ‘modern slavery’ as including eight types of serious exploitation:
- Trafficking in persons
- Slavery
- Servitude
- Forced marriage
- Forced labour
- Debt bondage
- The worst forms of child labour
- Deceptive recruiting for labour or services.
The U.K. Modern Slavery Act 2015 defines ‘modern slavery’ as encompassing human trafficking and all forms of exploitation, involving:
- The means: coercive behaviour
- The purpose: exploitation.
Operations
MyEmpire conducts business in Australia and the United Kingdom. It has no operations, joint ventures or partnerships in countries reported to have a high prevalence of modern slavery practises by the Global Slavery Index.
MyEmpire’s employee workforce is subject to the requirements of relevant local labour laws and regulations, including the Australian Fair Work Act 2009 (Cth), and the United Kingdom’s National Minimum Wage Act 1998 and Employee Rights Act 1996.
As such, MyEmpire has assessed the risk of modern slavery in its operations as low.
Supply Chains
Area | Exposure to Modern Slavery Risks |
Technology and hardware | Electronics is considered a high-risk industry globally. MyEmpire procures hardware from globally recognised Tier 1 providers (Technopedia, 2023), who as mandatory reporting entities, have clear strategies in reducing modern slavery risks in their supply chains. Where possible, purchasing occurs directly with the supplier. MyEmpire has assessed this to be a low modern slavery risk. |
Professional Services
| MyEmpire services are provided by Australian and United Kingdom registered and domiciled firms. MyEmpire has close working relationships with other professional service providers including insurances, security auditors, legal teams, and accountants. MyEmpire has assessed this to be a low modern slavery risk. |
Staff apparel and merchandise | Textiles is considered a high-risk industry globally. MyEmpire procures staff apparel and merchandise from a local supplier, who will primarily source from China. MyEmpire procures low quantities of goods from this sector. MyEmpire has assessed this to be a low modern slavery risk. |
Travel | MyEmpire primarily conducts its operations remotely (i.e., its online meetings and engagement), however, on occasion consultants may be required to travel domestically within Australia, or, due to its operations, internationally. Overall, travel remains very limited due to the nature of MyEmpire’s operations. MyEmpire utilises local travel agencies or book directly with national airline carriers and hotels. MyEmpire has assessed this to be a low modern slavery risk. |
Actions Taken to Address Risks of Modern Slavery
- Supply Chain Due Diligence: MyEmpire will endeavour to take steps to assess and manage the risks of modern slavery in supply chains. This includes, but is not limited to, evaluating the practices of suppliers and ensuring that they comply with the principles outlined in this Policy, especially with respect to slavery and human trafficking.
- Supplier Contracts: MyEmpire will endeavour to include specific clauses in supplier contracts that require suppliers to adhere to our commitment against modern slavery. MyEmpire reserves the right to terminate contracts with suppliers who fail to comply with these principles.
- Employee Awareness and Training: MyEmpire will endeavour to provide training to employees and management to ensure awareness of the risks of modern slavery and to encourage a culture that promotes ethical conduct.
- Reporting Mechanisms: Employees, suppliers, and other stakeholders can report concerns related to modern slavery directly to MyEmpire via the ‘Contact Us’ page on the MyEmpire website. Whistleblower protection measures are in place to ensure that individuals feel safe reporting such concerns. Alternatively, to report modern slavery in Australia call the Australian Federal Police on 131 237 or report through their website www.afp.gov.au. In the United Kingdom contact the Modern Slavery Helpline on 08000 121 700. In emergencies, where there is immediate danger, call Triple 0 (000) in Australia or Triple 9 (999) in the United Kingdom.
Measuring the Effectiveness of Above Actions
- Risk Assessment: MyEmpire will conduct regular risk assessments to identify and address any potential areas of vulnerability to slavery and human trafficking in our operations and supply chains.
- Continuous Improvement: MyEmpire is committed to continuously reviewing and improving its practices to address the risks of modern slavery. This includes regular updates to this statement to reflect evolving standards and best practices.
Communication
This Modern Slavery Statement will be communicated internally to all employees and externally to relevant stakeholders, including suppliers and customers. It will also be made available to the public on MyEmpire’s website.
Review and Update
This statement will be reviewed annually and updated as necessary to ensure its effectiveness and compliance with applicable laws and regulations.
Responsibility
The Company Directors are responsible for implementing and monitoring this statement, including overseeing risk assessments, training programs, and reporting mechanisms.
Approval
This Modern Slavery Statement has been approved by Alex Woerndle and Carl Woerndle, on 7/8/2024.
MyEmpire Group Pty Ltd is committed to a zero-tolerance approach towards modern slavery and will take all reasonable steps to ensure that business operations and supply chains are free from these practices.
Alex Woerndle Co-Founder / CEO 7/8/2024
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Carl Woerndle Co-Founder / Managing Director 7/8/2024
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MyEmpire Group Pty Ltd ABN 36 133 227 906
Suite 2.04, 550 Lonsdale Street, Melbourne VIC 3000, Australia
MyEmpire Group Ltd CN 14391538
101 New Cavendish Street, 1st Floor South, London, W1W6XH, UK
E: [email protected] W: myempire.group