Introduction

This Modern Slavery Statement is made on behalf of On the Nose pursuant to the Modern Slavery Act 2018 (Cth). This Statement sets out the actions taken by On the Nose to address modern slavery risks across our business operations and supply chains.

Our Business, Structure & Operations

On the Nose was established in 2000 as a supplier of ready made optical products for sale in pharmacy and giftware stores throughout Australasia;  manufactured to specification by selected manufacturers in China, Hong Kong and Taiwan.

Our Position on Modern Slavery

We reject any form of modern slavery such as servitude, human trafficking, forced labour and marriage, child labour and debt bondage. We strive to implement controls to attempt to ensure it does not occur within our business operations and supply chains.

We respect the human rights of our employees, clients and those of our suppliers and business partners. We aim to identify and manage risks related to human rights across our business and through our supply chain management. Our position is set out in our Modern Slavery Policy.

On the Nose is committed to strong corporate governance so that our decisions and actions are based on transparency, integrity and honesty, which promote the long-term sustainability and ongoing success of our business. We strive to maintain high ethical standards in our business practices. Our employment contract sets out the standards of behaviour we expect of our businesses and employees. On the Nose expressly commits to human rights by rejecting any form of modern slavery or human trafficking.

Ethics & Conduct

Building a culture that supports and enables us to achieve our purpose, vision and strategy in an ethical and responsible manner is a strategic priority for On the Nose. Our expectations on modern slavery apply to everyone who represents On the Nose, as outlined in our employment contract.

Our Workplace

On the Nose strives to ensure compliance with relevant laws, community expectations and high ethical standards relating to our commitment to human rights and risks of modern slavery practices. We aim to respect differences in beliefs and ideas to foster an inclusive workforce where people are treated with courtesy and dignity. On the Nose is committed to supporting a safe and healthy workforce for everyone, where discrimination, bullying, harassment and vilification are not tolerated.

Corporate & Social Responsibility

We have considered how we can help make a difference to some of the world’s most pressing social challenges within our sphere of influence. We seek to promote reduction of poverty and promotion of health and wellbeing through continuous donations of reading glasses to some of the worlds most disadvantaged communities where clear vision is the gateway to improved education and better living standards.

Training & Awareness

On the Nose is committed to upholding our strong legal, ethical and responsible culture. Our commitment to human rights is part of this culture and is expressly set out in our Modern Slavery Policy. Compliance with this is critical to enable us to deliver our strategy and create long-term value. Our employees must comply with all relevant laws and regulations as well as the technical and ethical requirements of relevant regulatory and professional bodies. Employees are encouraged to report any genuine concerns about modern slavery within our business operations or supply chains. All On the Nose employees and businesses are responsible for adherence to ethical, legal, and policy requirements that apply to their employment and for reporting any suspected breaches of law or employment contract. We have provided our Modern Slavery Policy to all staff and to those businesses in which we hold an equity interest and provided some training to assist our staff and equity-owned businesses to understand what modern slavery is, what circumstances may be a risk and how to report any potential issues.

Our Supply Chain

Our supply chain includes sales agencies, manufacturers, IT service providers, other service providers and professional services firms, located in China, Taiwan and in Australia. Based on sector and supply chain profile, the risk of modern slavery practices is real. On the Nose acknowledges the potential for exposure to the risk of modern slavery in our business operations and supply chains, such as in procurement of merchandise and has attempted to identify these and engage with the relevant parties to communicate On the Nose’s position and address any risk of modern slavery. On the Nose aims to build supportive, transparent and collaborative relationships with suppliers. We expect our suppliers and strategic partners to take appropriate steps to attempt to ensure that their organisation does not engage in, or inadvertently condone, modern slavery, including that their employees and contractors work in decent and safe conditions, and that no human trafficking, forced labour, child labour or other forms of modern slavery is employed in the delivery of products or services to On the Nose. We encourage our suppliers and strategic partners to manage their business and supply chain in a manner that upholds human rights and rejects modern slavery.

The following steps have been taken to address modern slavery risks within our supply chains:

1. In new arrangements, we endeavour to specifically refer to modern slavery and require both parties to use reasonable endeavours to avoid modern slavery practices.
2. Identified the broad operations and overall supply chain structure where modern slavery risks are likely to be most significant.
3. We strive to act legally, ethically and responsibly in all our dealings.
4. On the Nose generally deals with other businesses that have an established reputation in the marketplace for high ethical standards, compliance with legal requirements, and good corporate culture.

Remediation Process

Our approach to remediation is to address each issue as it arises, on a case-by-case basis and apply principles of fairness, and respect for human rights. No remediation has been required as of the date of this Statement, although the processes and procedures have been put in place, which are designed to reduce the risk of modern slavery practices within our business operations and supply chains.

Continuous Improvement

We aim to create an enhanced understanding of modern slavery risks within our business operations and supply chains by:

• continuing to review and improve relevant policies and commercial arrangements to reference modern slavery
• continually improving staff awareness of modern slavery risks enhancing due diligence and risk management processes for selection and screening of potential partners to include consideration of modern slavery risks
• assessing our practices and procedures against the requirements of the Modern Slavery Act 2018 (Cth)