Anti-Human Trafficking and Modern Slavery Policy

Effective: 1 August 2021


This policy sets out Toll’s position against human trafficking and modern slavery.


This policy applies to all companies and other entities (including joint ventures), employees and representatives of and within the Toll Group (Toll) and we expect all contractors, subcontractors and business partners that Toll engages to apply similar standards when working with us.


Toll is committed to acting ethically and with integrity and transparency in all business dealings. Toll respects ethical labour practices and values and promotes diversity. Consistent with these principles, Toll has a zero tolerance approach to any form of modern slavery in its operations or supply chain. Modern slavery encompasses servitude, forced labour, debt bondage and human trafficking. All employees, contractors and sub-contractors must not engage in any practices of modern slavery or human trafficking. This includes:

  • Using deceptive or coercive practices during recruitment or employment, such as making material misrepresentations about the key terms and conditions of employment; 
  • Procuring commercial sex acts; 
  • Destroying, concealing, confiscating or otherwise denying access to any employee’s identity or immigration documents (for example passports or drivers’ licenses); 
  • Providing or arranging housing that fails to meet host country housing and safety standards; 
  • Employing any child under the age of 15; 
  • Using forced labour in the performance of any contract; 
  • Failing to provide an employee contract, recruitment agreement or other required work document in writing (where one is required by law); 
  • Using recruiters or suppliers that do not comply with local labour laws; and 
  • Charging employees recruitment fees.

Breaches of this Policy

All suspected breaches will be investigated and appropriate disciplinary and remedial action taken. Employees who do not strictly comply with this policy may face disciplinary action, including formal warnings and termination.

Further Information

For further information contact your manager, your Human Resources representative or Group Compliance & Security.


Toll Modern Slavery Act FY2023 Statement

pdf | 0.20MB

Anti-Human Trafficking and Modern Slavery Policy 2021

pdf | 0.29MB