Modern Slavery Statement

This Modern Slavery Statement (Statement) is made in accordance with the Australian Modern Slavery Act 2018 (Cth). It applies to and describes the steps taken by Order-in PTY LTD and its subsidiaries to mitigate modern slavery in the Group’s businesses and supply chains

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Modern Slavery is a heinous crime and a morally reprehensible act that deprives a person's liberty and dignity for another person's gain. It is a real problem for millions of people worldwide, including many in developed countries, who are being kept and exploited in various forms of Slavery. Every company is at risk of being involved in this crime through its operations and its supply chain.

At EatFirst, we have a zero-tolerance approach to modern Slavery and are fully committed to preventing Slavery and human trafficking in our operation and supply chain. We have taken concrete steps to tackle Modern Slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business and to implement steps to prevent Slavery and human trafficking.

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Organisational Structure

EatFirst operates in the foodservice sector as the leading online marketplace for corporate catering. At EatFirst, we aim to offer customers easy access to the best local caterers and provide expert catering advice.

Our services include Corporate catering, pantry supplies, staff meal plans, functions and events, as well as and working from home solutions. We are currently operating in Australia, New Zealand, Singapore, the UK, Netherlands and Germany. EatFirst employs over 30 staff in Australia, and our APAC head office is located in Sydney. The management team and employees use their passion for great food and understanding of technology to provide our customers with exceptional service and our food partners with valuable industry trends and insight.

Over the last 20 years, EatFirst has established a relationship of trust and integrity with over 1000 suppliers, which is built upon mutually beneficial factors. Corporate caterers, cafes, fast food chains and pantry suppliers have chosen EatFirst as their preferred partner to expand their activities and grow their revenues. Our supplier selection and onboarding procedure include due diligence of the supplier's reputation, respect for the law, compliance with health, safety and environmental standards.

EatFirst core values are Ethics, Boldness, Responsibility and Teamwork. We will use these values in our dedication to comply with the Modern Slavery Act of 2018

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Risk Assessment

To improve our understanding of this risk, we have undertaken an initial assessment to identify the risks of modern Slavery. We have assessed these risks into two broad categories:

In our own employment practices

As a technology / professional services company , we are of the view that the risk of modern slavery in relation to our people is low, due to the level of skills and expertise of our resources and the countries within which our workforce operates.

In our supply chain: the business services rendered by suppliers

EatFirst engages with suppliers and outsourced service providers (collectively vendors) locally and nationally . Certain products and services may have a higher risk of modern slavery because of the way they are produced, provided or used. EatFirst is committed to understanding the risk of modern slavery that may be prevalent amongst our suppliers to ensure we consider the risk and reputational impact of doing business with a vendor. We have identified potential risks into 2 tiers

Due diligence & policy

In our own employment practice

EatFirst is committed to ensuring that our recruitment screening and selection process provides equal opportunity for applicants. Policy requirements mandate that applicants are shortlisted, interviewed and hired based solely on their ability to meet the inherent requirements of the position, avoiding any unlawful discrimination or bias.

The recruitment and selection procedures follow a set process whereby standard contracts of employment are issued to successful applicants, and contracts of employment comply with the relevant requirements of the Fair Work Act 2009. EatFirst remuneration and performance review strives to create a work environment that motivates and enables our people to perform to the best of their abilities and develop as professionals.

EatFirst operates the following policies for identifying and preventing Slavery and human trafficking in our operations and supply chain:

  1. EatFirst Statement - Our statement sets out the core values which we expect to be observed throughout the company. This includes the expected highest standards of integrity and behaviour in all its dealings with its stakeholders and society at large
  2. Whistleblower Policy - We encourage any employees and customers to report any suspicion of Slavery or human trafficking without fear of retaliation. We have a whistleblower form available in that effect.

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In our supply chain

We are committed to ensuring that our suppliers adhere to the highest standards of ethics. EatFirst conducts due diligence on all new suppliers during the onboarding procedure and on existing suppliers at regular intervals.

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1. Code of Conduct

  • Supplier's agreement clause - Suppliers are required to declare that they adhere to the terms and principles of our policies and ensure that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labour.
  • Food partner approval - Prior to trading, all suppliers undergo a food partner approval process in which they are expected to provide documented evidence of compliance with EatFirst food safety and legality standards, and, where applicable, their Modern Slavery Statement.
  • Corporate social responsibility:
  • Sustainability - We’re working hard with our food partners to increase sustainability practices for all catered events and functions. In that effect we have included a sustainability rating for our corporate caterers, in the form of green leaves.
  • Social enterprise and Indigenous business - We want to support businesses making an impact in the community and have been doing so since inception.
  • Fund raising initiative - Giving back to the community has always been a part of who we are. Oz Harvest and the Cancer council are among the few beneficiaries of EatFirst generous donations.
  • EatFirst's ethic - We don't impose unreasonable demands on suppliers. Excessive production targets or squeezed margins makes it more tempting for suppliers to cut corners or tolerate unethical practices.

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2. Annual Survey

  • Purpose - This survey is a tool to designed to facilitate collaborative two way engagement between EatFirst and food partners. It assist us in learning more about our suppliers operations and their strengths and weaknesses when it comes to addressing modern slavery risks.
  • Framework - The survey's contribution manifest in four parts: Auditing the suppliers, and their health and safety standards, Assessing risks in the provision of a particular risk, Requiring improvements to substandard employment practices when relevant and Sanctioning suppliers that fail to improve their performance in line with our requirements

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3. Spot Checks

  • Unannounced spot checks - We adopt a risk-based approach, so more checks are carried out on suppliers or parts of the business that pose the most risk.

Measuring Performances

We acknowledge that given the relative infancy of the formal regulatory regime relating to modern Slavery in Australia, the methods of modern Slavery due diligence and remediation are constantly being developed and refined.

EatFirst has defined a set of key performance indicators and controls to combat modern Slavery and human trafficking in our organisation and supply chain. These include:

  1. How many employees have completed mandatory training
  2. How many suppliers have filled out our ethics questionnaire
  3. How many suppliers have rolled out an awareness and training programme that is equivalent to ours

EatFirst understand that human risks are not static and that we must build in monitoring and continuous review.

Awareness and Training

We have in place a comprehensive code of conduct that includes fairness, nondiscriminatory reporting, respect for human dignity and human rights, social justice, health and safety and ethics. All employees are instructed on this Policy upon commencing employment.

We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.

Our statement sets out the core values which we expect to be observed throughout the company. This includes the expected highest standards of integrity and behaviour in all its dealings with its stakeholders and society at large.

How employees should report suspicions of modern Slavery:

In addition to the awareness programme, EatFirst has rolled out an Anti-Slavery resource e-learning course to all employees, which covers:

  • What is Modern Slavery?
  • Types of Modern Slavery
  • Who is responsible for addressing Modern Slavery?
  • What can you do?

The learning outcomes include:

  • Understand various forms of Modern Slavery in which people can be held and exploited
  • The size of the problem and the risk to our organisation
  • How employees can identify the signs of Slavery and human trafficking, including unrealistically low prices
  • How employees should respond if they suspect Slavery or human trafficking
  • How suppliers can escalate potential slavery or human trafficking issues to the relevant people in their own organisation
  • What external help is available for the victims of Slavery
  • What terms and guidance should be provided to suppliers in relation slavery policies and controls

Going Forward

We understand that tackling modern Slavery within businesses and their supply chain requires a continuous commitment.

Our current processes have led us to assess the risk of Modern Slavery to below within our own operation. However, that risk is higher in our supply chain, more specifically in the second tier. Our future plan to further mitigate the risk of Modern Slavery includes

In our own practice

  • Keep a relevant awareness and training program so all employees can easily identify risks associated with Modern Slavery.
  • Revise and tailor purchasing practices reflecting a responsible approach.

In our supply chain

  • Fine-tune external policies related to modern Slavery; these include code of conduct, due diligence questionnaire, audit in the form of spot checks and supplier statement of conformity

To date, we haven't been made aware of any allegations of human trafficking or slavery activities against any of our suppliers, but if we were, then we would act immediately against the supplier and report it to the authorities. We will continue to monitor the effectiveness of our procedures and review annually what improvements can be made to strengthen our stance against modern Slavery.

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