Modern Slavery Act Statement

28 September 2017

Toll Holdings Limited (Australian registered Company Number 006 592 089 and its subsidiaries (the Toll Group of
Companies “Toll”) is the Asia Pacific region’s leading provider of logistics services with approximately 40,000 people
across some 1,200 locations in more than 50 countries.

Our Business

Toll provides customers across the globe with an enormously diverse range of transport services and logistics solutions. As at 1 July 2017, Toll’s business was re-organised into three divisions, as set out below:

 

  • Global Forwarding: provides a full suite of international freight forwarding from complex supply chain solutions to port-to-port freight forwarding, specialising in Asia inbound and outbound trade lanes.
  • Global Logistics: specialist contract logistics division, which provides a broad range of sophisticated transport, warehousing and value-added services around the Asia Pacific region, including warehouse logistics, mining services, energy logistics, dedicated transport services, liquid distribution, relocation management, remote and resource logistics, aviation services and helicopter services.
  • Global Express: provides express freight within Australia and New Zealand, and globally via a network of operations and agencies across the Asia Pacific region. Also provides the following services Australia-wide: B2C, consumer and home deliveries, heavy haulage, project services and business support services ranging from integrated communication solutions to strategic recruitment services.

Our Policies

Toll invests time and expertise in ensuring that it makes a positive contribution in all of the jurisdictions in which it operates. To that end, we have developed a range of company policies, including in the areas of business ethics, workplace relations, occupational health & safety and environmental management. Toll considers that, on the whole, this suite of
policies provides the appropriate environment so that we work to live up to our ethical standards and do not knowingly allow human slavery or abuse to enter our business or supply chain.

Toll’s governance documents that cover the types of activities contemplated under the Modern Slavery Act include:

  • Toll Code of Practice;
  • Toll Ethical Employment Policy; and
  • Toll Group Protected Disclosure Policy.
Specifically, Toll’s Ethical Employment Policy provides that:

Human Rights

We respect the rights and interests of the communities in which we operate and the individuals with whom we interact. Toll will treat all employees (and business partners) with respect and dignity and will not use corporal punishment, threats of violence or other forms of abuse, physical coercion or harassment on any individual, nor condone such conduct in connection with any aspect of its business.

Forced and Child/Youth Labour

Toll will play a positive role in helping to eliminate forced and child labour by ensuring the employment of personnel meets with relevant local legislation and Labour Conventions.
Toll will not employ any person in a particular country who has not yet reached the older of:

  1. the minimum age for admission to employment or work; or
  2. the minimum age for completion of compulsory schooling.

In any event, Toll will not employ a person that has not yet reached the age of 15.
Toll will not condone or engage in any form of forced labour or child labour in connection with any aspect of its business. Toll will also not condone the use of any form of forced or child labour by any other third party on a Toll site.

Freedom of Assembly and Association

Toll recognises each employee’s right to be, or not to be, a member of or to be represented by a union or labour organisation and to partake in lawful activities to pursue the interests of the member group.

Diversity & Equal Opportunity

Toll recognises and values the contributions of people with varying capabilities, experience and perspectives. Toll has developed a Diversity & Equal Opportunity Policy which supports that we are committed to creating a workplace where all employees feel encouraged and free to bring a variety of approaches and ideas. Behaviour relating to discrimination, harassment, bullying, victimisation, vilification and violence is not tolerated or accepted at Toll.

Employment Conditions

Toll will, at a minimum; comply with all local employment legislation. Toll endeavours to compensate both male and female employees on the principle of equal pay for equal work.

 

These commitments are also set out in our Group Code of Practice, which can be found here.

Toll has a Toll Group Supplier Code of Practice which includes the requirement to comply with all employment laws and ethical labour policies.  All Toll contractors, consultants, vendors and suppliers must agree and comply with Toll’s Supplier Code of Practice. Toll’s procurement terms and condition make it a condition of engagement that any third party suppliers do not engage in activities that are inconsistent with this policy – when acting on behalf of Toll or otherwise.

The Code reserves the right for Toll to audit suppliers and their operations to ensure compliance. Toll can take any action deemed appropriate, including termination, if suppliers do not follow the Code.

Our Compliance Framework

Toll’s Policies are supported by Toll’s compliance framework, which comprise the following:

  1. Compliance reporting – regular compliance reporting is provided by management to Toll’s Board of directors and Board committees.
  2. Staff training - Toll provides training to its staff to reinforce compliance with Toll’s Ethical Employment Policy. The training is required to be conducted with new and existing staff.
  3. Audit and Assurance - Toll undertakes an Internal Audit and Assurance program which evaluates control and compliance processes on a risk basis. Depending on the risk assessment, such audits may include compliance with regulatory risks and company policy associated with labour laws, working hours, employee pay levels, and adherence to employee ‘right to work’/work permit requirements.
  4. Incident monitoring and escalation - Toll operates a global Disclosure Hotline which enables employees and contractors to report suspected misconduct anonymously and via an independent reporting line. Fraud, Improper Conduct (including dishonest, illegal or corrupt conduct) or Code of Practice breaches relating to employees, agents, contractors or suppliers can be reported through the hotline. All reported allegations are reviewed and appropriate investigations conducted, that include learnings, corrective actions and disciplinary action.


Toll will continue to review and update its policies, practices and procedures as required to maintain appropriate safeguards against any mistreatment of persons involved in its supply chain or its business.

Assessing our Risk and Priorities

During the reporting year, Toll commenced a Compliance / Business Integrity and Security Threat and Vulnerability Assessment, which included consideration of human trafficking and modern slavery as a compliance threat and input from the Global Slavery Index. This assessment has been completed and will be used to inform our ongoing business integrity program, including:

  • continuous improvement of governance frameworks, policies and processes, which will include the development of an Anti-Modern Slavery Policy;
  • our internal audit and assurance activities; and
  • tailoring our awareness and training activities to high risk roles, activities and geographies.

During the reporting year Toll also commenced a review of employee screening processes and will be implementing enhancements, including widening the scope of right to work verification to include all employees, contractors and subcontractors in Australia. Toll is also assessing options to extend right to work checks to Toll’s countries of operation identified as high risk.

Training and Awareness

Toll conducts online and face to face compliance training with its employees to reinforce compliance with Toll’s Ethical Employment Policy and Code of Practice. The training is conducted with new and existing employees. This training advises employees of ethics and legal principles that contribute to a culture of legal awareness and ethical practice within
Toll Group.


This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015(UK) and constitutes Toll’s slavery and human trafficking statement for the financial year ending on 31 March 2017. Enquiries should be directed to Toll’s Chief Compliance and Security Officer.