MODERN SLAVERY POLICY

Focused Mental Education Pty Ltd (ABN 56 678 167 765) (“FME”, “we”, “us”) has zero tolerance for modern slavery in any form. This policy explains what we prohibit, how we protect the people who work with us, what we expect of our suppliers, and how anyone can raise a concern.

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In summary: we never use or benefit from forced labour, child labour, human trafficking or any other form of modern slavery. We engage our people directly and fairly, we check our suppliers, we train our team every year, and anyone can report a concern to us or to the authorities without fear of retaliation.

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1. About this policy

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This policy applies to everyone who works for or with FME, including our director, any employees, our subcontracted instructors and anyone acting on our behalf. It covers all of our services, including Mental Health First Aid training, workplace mental health and psychosocial hazards training and consultancy, counselling and NDIS supports, whether delivered face to face anywhere in Australia or online. It also covers everything we buy.

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This page is the public version of our internal Modern Slavery Policy (FME-POL-MSP). We keep the two consistent.

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What modern slavery means. Modern slavery has the meaning in the Modern Slavery Act 2018 (Cth). It includes trafficking in persons, slavery, servitude, forced marriage, forced labour, deceptive recruiting, debt bondage and the worst forms of child labour.

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2. Our commitment

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Our work is about mental health, wellbeing and psychologically safe workplaces. Respecting the human rights and dignity of every worker, in our own business and in our supply chain, is part of that work. We take reasonable steps, in proportion to our size and risks, to prevent, identify, reduce and remedy modern slavery.

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Most of our clients are NSW Government agencies, which have legal duties to keep modern slavery out of what they buy. We aim to meet and exceed what they expect of their suppliers.

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3. Our business and supply chain

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FME is a small Australian company based in Mount Annan, NSW. Our team is our director and a small group of professionally qualified Mental Health First Aid instructors, based in Australia, whom we engage directly. We do not use recruiters, labour hire or worker housing.

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The main goods and services we buy include course licences and materials, software and IT, branded workwear, printing, venues, catering, travel and accommodation, and professional services. We know that some of these, especially workwear, electronics and venue services such as cleaning and catering, carry a higher risk of modern slavery in global supply chains, so that is where we focus our checks.

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4. What we prohibit

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Nobody working for FME or on our behalf may:

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• use, take part in or knowingly benefit from forced labour, servitude, debt bondage, deceptive recruiting, forced marriage, human trafficking or any other form of modern slavery

• use child labour or the worst forms of child labour. We do not engage anyone under 18 to work for us

• withhold, confiscate or destroy anyone’s passport, visa or other identity documents

• discriminate against anyone before hiring, at work or when they leave, including on the basis of race or colour, sex, religion, political opinion, national extraction or social origin, age, HIV/AIDS status, disability, nationality, sexual orientation, gender identity, family or carer responsibilities, or trade union membership or activities

• charge workers or job seekers recruitment fees or related costs. We pay these costs, including the cost of the FME branded uniform our instructors wear

• procure commercial sex acts while working for us or travelling at our expense

• use threats, deception, debt or control of pay or documents to make someone work or stop them leaving.

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5. How we protect workers

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Everyone who works with us, including our subcontractors:

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• can end their work with us at any time without financial penalty, after giving reasonable notice

• is paid at least what the law requires, in full and on time, with no unlawful deductions

• has the right to join a trade union, bargain collectively and take part in peaceful assembly

• receives a clear written agreement, in a language they understand, before they start

• has their age, identity and right to work in Australia checked before they start. We never keep original documents, and we keep only the information we need

• works in a safe environment, including protection from psychosocial hazards

• can raise a concern without fear of retaliation.

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We do not provide or arrange housing for workers. If we ever do, for example when travelling for work, it will meet Australian housing and safety standards and will never be used to control anyone.

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6. Our suppliers

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Our Supplier Code of Conduct (FME-POL-SCC) sets the same standards for our suppliers. We require our suppliers to:

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• meet the standards in sections 4 and 5 of this policy for their own workers

• have written policies on these topics, or adopt our Supplier Code of Conduct

• complete our modern slavery risk assessment questionnaire before we start working with them and at least once a year, if they supply higher risk goods or services. For lower risk suppliers, we review their published modern slavery statement each year

• apply the same standards to their own suppliers, and tell us promptly if they find a problem.

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If a supplier falls short, we first work with them to fix it and to put things right for any affected workers. We may stop using a supplier that will not cooperate or commits a serious breach.

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7. How we assess and manage risk

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Every year we run a continuous improvement program in which we:

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• assess modern slavery risk in our own operations and our supply chain

• check our suppliers, giving most attention to higher risk goods and services

• offer each of our workers a voluntary, confidential check of anything that could make them vulnerable to exploitation, so we can support them

• set improvement actions and track whether they work.

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Our approach follows the UN Guiding Principles on Business and Human Rights and the NSW Anti-slavery Commissioner’s Guidance on Reasonable Steps.

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8. Training

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Everyone who works for FME completes modern slavery awareness training when they start and at least once a year. It covers what modern slavery looks like, our rules, and how to respond and report safely.

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Because we provide counselling and NDIS supports, our team may meet people who are at risk of exploitation. They are trained to put safety first, to respond calmly and respectfully, and to connect people with the right help.

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9. Raising a concern

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Anyone can tell us about a concern relating to modern slavery, human trafficking or child labour, including workers, suppliers and their workers, clients, participants and members of the public. You can contact us by phone, email or post (see section 12), and you can stay anonymous if you prefer.

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We acknowledge concerns within 2 business days where we can contact you. We keep your identity confidential and we will not tolerate retaliation against anyone who raises a concern in good faith.

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You can also go directly to these services:

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• Emergency: if anyone is in immediate danger, call Triple Zero (000)

• Australian Federal Police: 131 237 (131 AFP), to report suspected modern slavery

• Crime Stoppers: 1800 333 000, to report anonymously

• NSW Anti-slavery Commissioner: 1800 FREEDOM (1800 37 33 36), for confidential 24 hour support and advice in NSW

• Anti-Slavery Australia: 02 9514 8115, for free and confidential legal and migration advice

• Translating and Interpreting Service: 131 450, if you need an interpreter.

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10. Accountability and putting things right

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A breach of this policy by anyone working for us is treated as serious and may end their engagement with FME. Suspected crimes are reported to the Australian Federal Police, with the safety and wishes of the affected person in mind.

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If we find that we have caused, contributed to or are linked to modern slavery, we will act to put things right. That means putting the safety and choices of the affected person first, connecting them with support, repaying any wages, fees or costs owed, working with suppliers to provide remedy, and cooperating fully with the authorities.

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11. Changes to this policy

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We review this policy at least once a year and whenever the law or our business changes. The current version is always the one published on this page, with its effective date shown at the bottom.

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12. How to contact us

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Questions about this policy, or a concern about modern slavery, can be directed to:

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Focused Mental Education Pty Ltd

PO Box 7370

Mount Annan NSW 2567

Email: info@fme.com.au

Phone: (02) 8044 3365

ABN 56 678 167 765

ACN 678 167 765

 

Effective date: Friday 6th November 2026

Last reviewed: Friday 6th November 2026