Modern Slavery Policy

1. Introduction

This Modern Slavery Policy and Statement outlines our commitment to identifying, assessing and addressing risks of modern slavery within our operations and supply chains.

Modern slavery includes slavery, servitude, forced labour, debt bondage, deceptive recruiting, child labour and human trafficking. We recognise that these practices can exist within global supply chains and across many industries.

We are committed to conducting our business ethically, transparently and in compliance with the Modern Slavery Act 2018 and other applicable laws.

2. Our Business and Operations

We are an Australian-based organisation providing goods and/or services to customers domestically and, where applicable, internationally.

Our operations are conducted in accordance with Australian workplace legislation and employment standards. We are committed to maintaining lawful, fair and safe working conditions for all employees and contractors.

3. Our Supply Chain

Our supply chain may include:

• Goods and materials sourced from Australian and international suppliers
• Components or finished products manufactured overseas
• Service providers engaged to support our operations

Some goods and materials may originate from jurisdictions where labour protections vary. As a result, potential modern slavery risks may arise within multi-tiered international supply chains.

4. Risk Assessment

The risk of modern slavery occurring within our direct Australian operations is considered low due to:

• Compliance with Australian employment laws
• Direct oversight of employment arrangements
• Transparent payroll and workplace practices

However, we recognise that risks may exist within upstream supply chains, particularly in:

Manufacturing environments involving complex subcontracting arrangements

Raw material extraction and processing

Industries or regions where labour protections may be weaker

5. Actions to Address Risk

To minimise the risk of modern slavery in our operations and supply chain, we undertake the following measures:

Supplier Selection
We seek to engage reputable suppliers and service providers that operate ethically and comply with applicable labour laws.

Due Diligence
Where reasonably practicable, we consider the source of goods and services and assess potential risk factors in supplier relationships.

Commercial Expectations
We expect suppliers to:

• Comply with applicable workplace and labour laws
• Prohibit forced labour, child labour and human trafficking
• Maintain fair and safe working conditions
• Act ethically and with integrity

Ongoing Monitoring
We periodically review supplier relationships and remain attentive to emerging risks.

Where credible concerns are identified, we will investigate and, where appropriate, reassess or terminate the supplier relationship.

6. Reporting Concerns

Employees, contractors, suppliers and other stakeholders are encouraged to report any concerns regarding unethical conduct or potential modern slavery risks.

Reports may be made to management and will be treated confidentially. We will investigate credible concerns and take appropriate corrective action where necessary.

7. Governance and Responsibility

Management is responsible for implementing this policy, monitoring risks and reviewing its effectiveness.

This policy will be reviewed annually or as required to ensure ongoing compliance with legal obligations and evolving best practice.

8. Continuous Improvement

We acknowledge that modern slavery risks can evolve over time. Accordingly, we are committed to continuous improvement in our risk assessment and due diligence processes.

We recognise that responsible business conduct requires ongoing vigilance and accountability.

Policy Approval

This Modern Slavery Policy and Statement has been approved by management.

Effective Date: 1st January 2024