Modern Slavery Policy

Start Technologies Pty Ltd trading as StartCloud ("StartCloud", "we", "us", "our") is committed to acting ethically and with integrity in all our business relationships. We are dedicated to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chains.

This policy applies to all persons working for us or on our behalf in any capacity, including employees, directors, contractors, consultants, and business partners.

We expect the same high standards from all of our suppliers, contractors, and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory, or trafficked labour, or anyone held in slavery or servitude.

Modern slavery is a serious crime and a violation of fundamental human rights. Under the Modern Slavery Act 2018 (Cth), modern slavery includes the following eight types of serious exploitation:

• Trafficking in persons: The recruitment, harbouring, or movement of people for the purpose of exploitation through force, fraud, or coercion
• Slavery: The status or condition of a person over whom powers of ownership are exercised
• Servitude: Where a person's labour is obtained by coercion, threat, or deception and they cannot reasonably be expected to leave
• Forced marriage: A marriage without genuine consent due to coercion, threat, or deception
• Forced labour: Work or service exacted under the menace of penalty and for which the person has not offered themselves voluntarily
• Debt bondage: Where a person's services are used to pay off a debt and the value is not reasonably applied to liquidate the debt
• Deceptive recruiting for labour or services: Recruiting a person through deception about the nature of the work
• Worst forms of child labour: Slavery, trafficking, debt bondage, or hazardous work involving children

StartCloud provides managed IT services, cybersecurity solutions, cloud computing, and networking services to businesses across Australia. Our operations include:

• Managed IT support and helpdesk services
• Cybersecurity monitoring, assessment, and remediation
• Cloud migration and management services
• Network infrastructure design and implementation
• Technology consulting and virtual CIO services

We operate primarily in Western Australia and employ a team of IT professionals. Our workforce consists of permanent employees and, on occasion, contractors who are engaged through reputable recruitment agencies.

We undertake due diligence when considering taking on new suppliers and regularly review our existing suppliers. Our due diligence includes:

• Evaluating the modern slavery and human trafficking risks of each new supplier
• Reviewing supplier policies and practices related to modern slavery
• Building long-term relationships with suppliers and making clear our expectations
• Invoking sanctions against suppliers that fail to improve their performance in line with our expectations

We assess the risk of modern slavery in our supply chain by considering factors such as the geographic location of suppliers, the industry sector, and the nature of the goods or services provided.

Our supply chain primarily consists of:

• Technology vendors: Hardware manufacturers, software providers, and cloud service providers (primarily major multinational corporations with established modern slavery policies)
• Professional services: Legal, accounting, and consulting firms
• Facilities and office supplies: Providers of office equipment, cleaning services, and maintenance
• Recruitment agencies: Providers of temporary and contract staff

We require our suppliers to:

• Comply with all applicable laws regarding modern slavery
• Have in place adequate procedures to identify and address modern slavery risks
• Permit us to audit their compliance upon reasonable request
• Notify us immediately if they become aware of any actual or suspected modern slavery

We encourage all workers, customers, and other business partners to report any concerns related to the direct activities or supply chains of the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.

Reports should be made to:

We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of our own business or our supply chain.

We provide training to relevant members of staff so that they understand:

• The basic principles of the Modern Slavery Act 2018
• How to identify the signs of modern slavery
• What steps to take if they suspect that modern slavery is taking place
• The external assistance available for victims of modern slavery

Our goal is to ensure that our employees are aware of the risks of modern slavery and human trafficking in our business and supply chains and understand how to report concerns.

This policy will be reviewed on an annual basis to ensure it remains effective and appropriate for our business. We will monitor the effectiveness of our actions by:

• Reviewing supplier due diligence processes annually
• Tracking and responding to any reported concerns
• Reviewing any incidents of non-compliance with this policy
• Assessing the level of communication and understanding across our business

We will continue to develop our approach to addressing modern slavery risks and will update this policy as our practices evolve.

This Modern Slavery Policy has been approved by the management of Start Technologies Pty Ltd trading as StartCloud.

We are committed to continuously improving our practices to combat slavery and human trafficking in our business and supply chain.