Governance

Code of Conduct

CTM maintains standards of conduct that apply to all staff, contractors and partners to ensure integrity and nurture a positive atmosphere of operation. Our key principles are:

  1. Always act with fairness, honesty, integrity and openness, respecting the opinions of others and treating all with equality and dignity.
  2. Promote the purpose, vision and values of CTM in all dealings, both internally and externally.
  3. Observe the laws, regulations and professional standards expected in each country in which CTM does business.
  4. Provide a positive and valued experience for those receiving our services both internally and externally.
  5. Take responsibility for your actions and decisions supporting CTM’s policies, procedures and decisions reflecting delegated authority in place across CTM to ensure that you do not exceed the authority of your position.

Privacy Statement

The Privacy Policy is to:

• Give transparency of CTM’s services;
• communicate the personal information handling practices of CTM and
• give individuals a better understanding of the way we handle their information.

Obligations

This Privacy Policy sets out how we comply with The Privacy Act (commonwealth 1988). In this privacy policy, ‘Personal Information’ means “information or an opinion about an identified individual who is reasonably identifiable: whether the information is true or not; and whether the information or opinion is recorded in a material form or not.

Collection of Personal Information

CTM endeavors to not collect, hold, use and disclose personal information. We will only collect personal information from you or third parties where such collection is necessary and directly related to our functions and activities and will always seek prior approval before doing so.

Use of the Personal Information

When personal information is collected, CTM only use this information for the purposes for which it was given to us, or for purposes which are directly related to one of our functions or activities, and we do not give it to government agencies, private sector organisations or anyone else unless one of the following applies:
• it is required or authorised by law
• the individual has given consent
• it will prevent or lessen a serious and imminent threat to somebody’s life or health

Data Security

We take steps to protect the personal information we hold against loss, unauthorised access, use, modification or disclosure, and against other misuses. These steps include password protection for accessing our electronic IT system, securing paper files in locked cabinets and physical access restrictions. CTM controls all types of data in compliance to ISO27001.

Access to Personal Information we hold

If an individual requests access to the personal information we hold about them or requests that we change that personal information, we will allow access or make the changes unless we consider that there is a sound reason under the amended Privacy Act or other relevant law to withhold the information, or not make the changes.

Complaints

If you think we may have breached your privacy you may contact us to make a complaint using the contact details below. In order to ensure that we fully understand the nature of your complaint and the outcome you are seeking; we prefer that you make your complaint in writing.

For further information about our complaint handling processes please contact us at support@ctmps.com

Cookies

Our website may use “cookies”. A cookie is a small text file that the website may place on your computer to improve your experience. You may choose to disable cookies in your browser but by doing so, you may be unable to access some advanced functions on the website.

Use and disclosure

We do not give personal information collected online to other agencies, organisations or anyone else without your consent unless you would reasonably expect, or have been told, that information of that kind is usually passed to those agencies, organisations or individuals, or the disclosure is otherwise required or authorised by law.

Data Accuracy and Security

We will delete or correct any personal information that we hold about you on request. We take reasonable steps to manage data stored on our servers to ensure data security.

Contact Us

If you have any enquiries or complaints about privacy, or if you wish to access or correct your personal information, please email us at support@ctmps.com or write to:
The Directors,
CTM Professional Services Pty Ltd,
Level 7, 474 Flinders St, Melbourne - 3000.

Changes to this privacy policy

Please note that the privacy policy may change from time to time.

Last updated: November 2022

Modern Slavery Statement

1. What is Modern Slavery?

Modern slavery is an international crime, affecting millions of people around the world - a growing global issue that transcends age, gender, and ethnicity. Unfortunately, vulnerable people from overseas as well as across Australia, are forced to work illegally against their will across many different sectors from agriculture, construction, hospitality, retail, manufacturing, and others.

2. Statement of Intent

Modern Slavery describes situations where offenders use coercion, threats, or deception to exploit victims and undermine their freedom (Commonwealth Modern Slavery Act, 2018). CTM Professional Services Pty. Ltd (CTM will be used further in the document) does not tolerate the existence of Modern Slavery in its business or supply chain.

This policy sets out the process by which CTM strives to ensure there is no Modern Slavery present in our business or supply chain and the manner in which employees of CTM can report any suspected instances of Modern Slavery.

3. Our organisation structure and supply chains

CTM is a private company limited by guarantee, incorporated in Melbourne, Australia. It is the coordinating entity for a network of independently owned and managed IT companies based around the world. For completeness, where our structure, operations, and supply chain have remained the same over the reporting period, we have re-stated the same information in this statement.

Our business uses professionally qualified people employed directly by CTM or seconded from a member firm in a limited number of countries. Our policies ensure fair treatment of our people around the world.

CTM utilise external suppliers for technology and services and performs due diligence as part of our commitment to identifying and preventing modern slavery.

3.1 Our Commitment

CTM’s modern slavery statement is made in fulfilment of the requirements of the Modern Slavery Act 2018 (Cth). The measurement and evaluation processes are comprised of practical indicators focused on three key impact groups: suppliers, alliance partners and contractors; clients; and CTM’s people. Information collected for the measurement and evaluation processes guides CTM’s continuous improvement approach to addressing modern slavery risks and informs reporting in future modern slavery statements.

3.2 Where we source

CTM source our technology products and services from companies throughout the world.

4. Application

This statement applies to all staff members including employees, contractors, and third parties that work on behalf of CTM at all locations.

5. Policy Statements

This policy focuses on how CTM is addressing Modern Slavery:

5.1 Review of supply chain

As part of our procurement processes, CTM regularly maps out our supply chain to the 2nd Tier. Key information includes supplier names, geographic locations, and categorized spending. The frequency we do this is yearly (November each year) and includes all suppliers of hardware, software, and services.

In addition to the above, CTM is committed to the continued undertaking of Supplier surveys:

  1. CTM supplies yearly surveys (every November) to our Tier 1 and Tier 2 suppliers on the topic of Modern Slavery.
  2. The Surveys are reviewed and assessed by the directorate for validity.
  3. Suppliers are given a chance to expand their response if CTM deems a response is too vague.
  4. CTM determines if the supplier is to continue to provide services as a member of our supply chain.
  5. Expect our suppliers to provide a Modern Slavery statement/plan if they meet the mandatory requirements for reporting.

Effective as of 2020 CTM regularly, reviews and assesses the effectiveness of our approach to reduce the risk of Modern Slavery across our suppliers. Utilizing data collection across the business, such as spending data, supplier surveys, and staff input.

5.2 Our policies in relation to slavery and human trafficking

CTM has established a zero-tolerance position on violations of Australia’s anti-human trafficking and anti-modern slavery laws. If we find breaches of these laws within our supply chain, we look to support companies in their efforts to comply with the legislation. Our values of Collaboration, Leadership, Excellence, Agility, Respect, and Responsibility, are the pillars of our culture. They embody everything that we do at CTM and how we do business. They outline the expectation of our people’s behaviour with colleagues, vendors, and people around the world. We seek to treat everyone fairly and consistently, creating a workplace and business environment that is open, transparent, and trusted.

Our policies and procedures relating to the Modern Slavery Act are in line with our culture and values. Our specific procedures to address modern slavery risk include:

  • A ‘Modern slavery policy’ for our people, which sets out the key issues and how we should respond including a process for raising concerns internally
  • An ethics hotline that allows for anonymous reports to be submitted by our people
  • A process for handling complaints raised by people outside of CTM
  • Employment policies that protect our people from unfair treatment and promote a fair and inclusive workplace
  • Robust recruitment processes in line with relevant employment laws
  • A ‘Procurement policy’ for how we deal with suppliers, a ‘Supplier Management Policy, and a code of conduct makes clear the standards we expect.

5.3 Modern Slavery Statement

In accordance with applicable legislation in the areas in which we operate, CTM publishes any required statements or notifications in relation to our efforts to address Modern Slavery in our business or supply chain.

5.4 Use of our Champions

  • We leverage existing people, policies, and processes in a continual improvement flow to further assist in identifying Modern Slavery risks. Example: Policies that are outlined in our procurement processes identify spending data per supplier. Processes used for staff hiring through employment services assist to identify Modern Slavery risks.
  • We have also assigned a group of staff (the ERT), selected across multiple teams to champion CTM’s approach to Modern Slavery. All staff has the ability to approach a known champion confidentially if they feel the need to discuss the topic of Modern Slavery or whistleblowing through CTM’s Modern Slavery Incident/Suspicion Reporting Process.
  • All employees of CTM must not engage in any conduct which would amount to a breach of any applicable Modern Slavery legislation in the region they work in.

5.5 Identification and Actions

  • This is a very sensitive matter and needs to be addressed in a considered way with a focus on people in harm’s way. CTM maintains the anonymity of whistleblowers and maintains a minimum exposure of the people involved. An action plan is defined by directors for each incident identified, if and when identified. In General, CTM enables suppliers, internal and external, an opportunity to respond to identification and work with CTM to create a plan of attack to further reduce the risk or eliminate the risk completely.
  • All employees and contractors of CTM are responsible for being alert towards any Modern Slavery practices that they may become aware of in our business or supply chain.
  • If any employee reasonably believes or suspects that Modern Slavery may be present in our supply chain or business, they MUST report it through CTM’s Modern Slavery Incident/Suspicion Reporting Process, as soon as possible.

5.6 Due diligence processes, risk assessment, and management

The implementation of our policies and procedures includes due diligence on suppliers that we engage with, in accordance with our procurement policy. To mitigate against this risk, we assess the companies that we deal with as part of the decision-making process for professional services and managed services.

When we admit a new partner, a thorough due diligence process takes place to ensure that the firm has a good reputation with appropriate practices in a number of areas including people and culture.

5.7 Key performance indicators to measure the effectiveness of steps being taken

We log complaints received via our ERT MDS reporting process and logged within our internal system..

5.8 Training

All employees of CTM have access to materials on understanding what Modern Slavery is, ways to spot Modern Slavery, and how to report Modern Slavery. CTM provides periodic training to staff members on the subject of modern slavery and our policies to address the risks to help increase education and awareness.

6. Legal & Policy Framework

The Compliance Policy set the foundation for CTM compliance with:

7. Review and Validity of statement

The Modern Slavery Statement is an active document and must be subject to independent review. Management review must be conducted according to CTM Governance Support Process at the end of every financial year.

This statement is reviewed by the Board of Directors and ERT every year from the effective date. If there is any modification, it must follow the approved validity process.

ISO27001

CTM wants to provide its customers with the assurance that all systems utilized in the delivery of its services are secure, reliable, and continually improved. The CTM Information Security Management System provides this assurance by facilitating policies, processes and the right technology solutions to protect the integrity, confidentiality and availability of data and systems. CTM is committed to maintaining this compliance into the future.

CTM is now ISO27001 certified.

ISO Cert