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ILLEGAL LOGGING POLICY
PURPOSE OF THIS POLICY
Freedom Furniture Australia Pty Ltd and each of its subsidiaries in Australia and New Zealand (Freedom, we, us, our) is committed to ensuring compliance with the laws designed to reduce the risks of products containing timber from illegal logging entering the Australian and New Zealand markets, including the Illegal Logging Prohibition Act 2012 (Cth) and Illegal Logging Prohibition Regulation 2012 (Cth) (Illegal Logging Laws).
As part of this commitment, Freedom takes steps to comply with its responsibilities under the Illegal Logging Laws as an importer of regulated timber products, which include obligations to undertake due diligence on a product prior to import and keep records of the due diligence undertaken.
The purpose of this Illegal Logging Policy is to:
WHAT IS ILLEGAL LOGGING?
Illegal logging occurs when logs are harvested from a forest or plantation without the required approvals under the relevant laws of the country in which the forest or plantation is located.
It is an offence under the Illegal Logging Laws to import products containing illegally logged timber into Australia. It is also an offence not to carry out and document due diligence on regulated timber product imports.
SCOPE OF THIS POLICY
This Policy applies to all persons working for or on behalf of Freedom, including employees, directors, officers, agents, contractors and consultants, insofar as they carry out work in connection with, or otherwise hold responsibilities in relation to, Freedom’s obligations under the Illegal Logging Law (referred to in this Policy as Team Members).
This Policy also applies to all of those who have, or seek to have, a business relationship with Freedom including suppliers, service providers and franchisees (referred to in this Policy as Business Partners).
OUR APPROACH AND COMMITMENTS
As an importer of regulated timber products, we are required to carry out a due diligence process for each product prior to import, to confirm there is low or no risk that the product contains illegally logged timber. Freedom is required to maintain a written due diligence system by the Illegal Logging Laws, which details the processes we use to comply with our due diligence requirements. Our due diligence system is contained in the document titled 'Due Diligence System – Importing Regulated Timber Products' (Due Diligence System).
The Due Diligence System outlines the processes that must be used to undertake the following steps prior to importing any regulated product:
Our policy is to only import regulated timber products if, after following the due diligence process, we have identified there is low or no risk that a product contains illegally logged timber. If we identify that this is the case, we can:
If we have identified there is a greater than low risk that a product (or a component of a product) may contain illegally logged timber, our policy is not to import the product and to inform our supplier of the outcome of our due diligence process.
OUR RECORD KEEPING PROCESS
Under the Illegal Logging Laws, we are required to keep records of all information gathered as part of our due diligence process for a minimum of 5 years from the day a product is imported. Section 7 of our Due Diligence System details the records that must be kept for each import of a regulated timber product.
Team Members must ensure that they follow requirements for creating and maintaining records so that we can show compliance with Illegal Logging Laws. For example, the Illegal Logging Laws require Freedom to assess and determine certain matters in a sequence and prior to importing products. To support compliance with record-keeping requirements, documents relating to a record for a proposed import must be dated accurately and promptly added to the record for that product.
RESPONSIBILITY
We are committed to giving our Team Members the appropriate systems and support to enable them to assist Freedom to meet its obligations under the Illegal Logging Laws, as required by a Team Member's role and responsibilities.
Team Members are required to comply with the Due Diligence System and the record keeping method outlined in this Policy when undertaking tasks in connection with the due diligence process for a regulated timber product.
Team Members must:
In addition to the above, Blue Rock Sourcing Solution Limited, in its capacity as Freedom’s off-shore quality assurance/quality compliance partner, must fulfil its contractual obligations with respect to ensuring Freedom’s compliance with Illegal Logging Laws.
Management must:
EXPECTATIONS OF BUSINESS PARTNERS
We expect our Business Partners to:
REPORTING OR RAISING A QUERY OR CONCERN
Anyone who has a query or concern about Freedom and illegal logging compliance is encouraged to raise their concern (anonymously, if desired) via our SpeakUp! channel at https://freedom.stoplinereport.com/, or for our Team Members via our digital workplace platform.
CONSEQUENCES OF NON-COMPLIANCE
Any non-compliance with this Policy by Team Members will lead to disciplinary action up to and including termination of employment or engagement.
Any actual or suspected non-compliance with this Policy by a Business Partner must be notified to us immediately. We require all Business Partners to cooperate in any investigation or related processes which we may initiate.
Any substantiated non-compliance with this Policy by a Business Partner or an entity in one of its supply chains may result in corrective action and the suspension or termination of the contractual relationship.
In all cases we reserve the right to inform relevant authorities.
COMMUNICATION
The existence of this Policy and its contents will be communicated to Team Members and Business Partners.
This Policy will be made available on our digital workplace platform and the Freedom website.
UPDATES TO THIS POLICY
The Policy will be reviewed every two years, or when there is a legislative or regulatory change. Amendments will be made with Board approval.
GOVERNANCE
This Policy has been approved by the Board of Greenlit Brands Pty Limited.