Modern Slavery Policy

SolidCo Pty Ltd
ABN 41 680 244 446

Modern Slavery Policy

Version 1.0

1. Purpose

SolidCo Pty Ltd (“SolidCo”, “we”, “our”, or “us”) is committed to conducting business ethically, responsibly, and with respect for human rights.

This Modern Slavery Policy outlines our commitment to preventing modern slavery, forced labour, child labour, human trafficking, debt bondage, servitude, and other forms of exploitation within our business operations and supply chain.

Although SolidCo is not currently required to report under the Australian Modern Slavery Act 2018 (Cth), we voluntarily adopt this policy to demonstrate our commitment to ethical business practices, responsible procurement, and transparent supplier management.

2. Scope

This policy applies to all people and organisations involved in, or connected with, SolidCo’s business activities, including:

• directors;
• employees;
• contractors;
• consultants;
• temporary workers;
• suppliers;
• service providers; and
• business partners engaged by SolidCo.

Where appropriate, suppliers may be requested to demonstrate compliance with this policy or provide evidence that they maintain equivalent ethical labour standards.

3. What is Modern Slavery?

Modern slavery describes serious forms of exploitation where a person cannot refuse or leave work because of threats, coercion, abuse of power, deception, or other forms of control.

Modern slavery may include:

• human trafficking;
• forced labour;
• child labour where prohibited by law;
• debt bondage;
• forced marriage;
• servitude;
• slavery;
• deceptive recruiting practices; and
• the worst forms of child labour.

Modern slavery can occur in any country, sector, or industry, including within complex international supply chains.

4. Our Commitment

SolidCo opposes all forms of modern slavery. We are committed to acting with integrity in our business dealings and to taking reasonable steps to reduce the risk of modern slavery occurring in our operations or supply chain.

SolidCo is committed to:

• respecting internationally recognised human rights;
• operating lawfully, ethically, and responsibly;
• opposing all forms of modern slavery and human exploitation;
• promoting fair and safe working conditions;
• procuring goods and services responsibly;
• working with reputable suppliers wherever reasonably practicable;
• encouraging transparency throughout our supply chain; and
• responding appropriately where modern slavery risks or concerns are identified.

5. Our Business

SolidCo is an Australian software development and digital services company. Our services may include:

• website development;
• web application development;
• managed hosting;
• website support and maintenance;
• cloud infrastructure management;
• software consulting;
• digital integrations; and
• related technology services.

Our operations are primarily office based and remote, using professional employees, contractors, and specialist service providers.

6. Our Supply Chain

SolidCo procures goods and services from a range of suppliers to support its business operations and client services. These may include:

• cloud hosting providers;
• domain name providers;
• software platforms;
• payment providers;
• accounting software providers;
• productivity software providers;
• security service providers;
• professional advisers;
• office equipment providers;
• IT hardware providers; and
• telecommunications providers.

The majority of our suppliers are established technology and professional service providers operating in Australia, the United Kingdom, the European Union, the United States, or other jurisdictions with mature regulatory frameworks.

We recognise that some suppliers may rely on broader international supply chains, including manufacturing, logistics, data centre infrastructure, hardware production, and subcontracted services. These areas may carry higher modern slavery risks.

7. Risk Assessment

Given the nature of our business, SolidCo currently assesses the overall inherent risk of modern slavery within its direct operations as low.

Potential areas of higher risk may include:

• IT hardware manufacturing;
• electronic component supply chains;
• international subcontracting;
• cloud infrastructure supply chains;
• data centre construction and facilities services;
• cleaning, logistics, and facilities services used by suppliers; and
• third party service providers operating in higher risk jurisdictions.

We will review these risks periodically and update our approach as our business, suppliers, and services evolve.

8. Supplier Expectations

SolidCo expects its suppliers and service providers to conduct their businesses ethically and in compliance with applicable laws.

We expect suppliers to:

• comply with applicable labour laws;
• comply with applicable modern slavery legislation;
• prohibit forced labour and human trafficking;
• prohibit unlawful child labour;
• provide safe and lawful working conditions;
• pay workers lawfully and fairly;
• respect freedom of association where legally permitted;
• maintain appropriate employment and wage records;
• avoid misleading or deceptive recruitment practices;
• ensure workers are not unlawfully charged recruitment fees; and
• notify SolidCo of any significant modern slavery concerns affecting services supplied to us.

Where concerns arise, we may seek additional information, require remediation, suspend work, or terminate supplier relationships where appropriate.

9. Due Diligence

SolidCo adopts a practical and proportionate approach to modern slavery due diligence. Our approach reflects the size and nature of our business.

Where appropriate, our due diligence measures may include:

• selecting reputable suppliers;
• considering supplier reputation during procurement;
• reviewing publicly available supplier information;
• reviewing supplier modern slavery statements, policies, or equivalent commitments where available;
• considering geographic and sector based risk factors;
• raising concerns with suppliers where unethical practices are identified;
• maintaining records of significant supplier relationships; and
• reviewing supplier arrangements where material risks arise.

As SolidCo grows, these due diligence processes may be expanded to include more formal supplier questionnaires, contractual clauses, and supplier reviews.

10. Reporting Concerns

Employees, contractors, suppliers, and other stakeholders are encouraged to report any concerns regarding suspected modern slavery, human trafficking, forced labour, child labour, or unethical labour practices connected with SolidCo’s operations or supply chain.

Reports may be made confidentially by starting a live chat on our website or by using the details on our Contact page.

Report a concern →

No person will be disadvantaged for making a genuine report in good faith.

11. Investigating Concerns

Where a modern slavery concern is identified, SolidCo will take reasonable and proportionate steps to assess the issue.

This may include:

• reviewing the reported concern;
• gathering relevant information;
• engaging with the relevant supplier or service provider;
• seeking evidence of remediation where appropriate;
• requiring corrective action;
• suspending or terminating supplier relationships where serious concerns are identified; and
• documenting significant findings and actions taken.

Our preference is to support effective remediation where possible, rather than immediately disengaging in a way that may worsen outcomes for affected workers. However, SolidCo may terminate relationships where a supplier refuses to address serious concerns.

12. Training and Awareness

Given the size of our organisation, formal modern slavery training is not currently mandatory.

However, directors and relevant personnel involved in procurement, supplier selection, and contractor engagement are expected to maintain awareness of:

• modern slavery risks;
• ethical sourcing practices;
• responsible supplier selection;
• warning signs of worker exploitation; and
• relevant Australian legislation.

Training requirements will be reviewed as the business develops.

13. Continuous Improvement

SolidCo is committed to continuously improving its approach to identifying, assessing, and reducing modern slavery risks.

This includes periodically reviewing:

• procurement practices;
• supplier relationships;
• risk assessments;
• internal policies;
• contractor engagement practices;
• reporting processes; and
• relevant legislative developments.

14. Compliance

Failure by employees or contractors to comply with this policy may result in appropriate action, including disciplinary action where applicable.

Suppliers that fail to meet acceptable ethical standards may have their contracts reviewed, suspended, or terminated.

15. Related Policies

This policy should be read alongside SolidCo’s other relevant policies and contractual documents, including:

• Privacy Policy;
• Terms & Conditions;
• Data Processing Addendum;
• Information Security Statement; and
• Code of Conduct, where applicable.

16. Legislative Framework

This policy supports SolidCo’s commitment to responsible business conduct and is informed by:

• Modern Slavery Act 2018 (Cth);
• relevant Australian State and Territory employment legislation;
• International Labour Organization core labour standards; and
• United Nations Guiding Principles on Business and Human Rights.

17. Approval

This policy has been approved by SolidCo Pty Ltd.

SolidCo Pty Ltd
ABN 41 680 244 446