‍Modern Slavery Statement

Modern slavery is a heinous crime and a morally reprehensible act that deprives a person of their liberty and dignity for another person’s gain. It is a real problem for millions of people around the world, 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 own operations and its supply chain.

At SoudCoh Pty Ltd, 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 potential modern slavery risks related to our business and to implement steps to prevent slavery and human trafficking during the financial year 2023-2024.

Our Business and Supply Chains

SoudCoh Pty Ltd was established in 2022 and is headquartered in Melbourne, Australia. Our business activities include business consulting, automations, business analysis, IT consulting and Technology Strategy. We maintain a commitment to ethical conduct and compliance with laws and regulations in all aspects of our operations.

We establish relationships of trust and integrity with all our clients and suppliers, which are built upon mutually beneficial factors. Our supplier selection and onboarding procedures include due diligence of the supplier’s reputation, respect for the law, compliance with health, safety, and environmental standards, and references.

We monitor our suppliers to remain aware of any potential allegations of human trafficking or slavery activities. If we became aware, we would respond immediately against the supplier, cease commercial dealings with the supplier, and report it to authorities.

Risk Assessment

In the past year, we conducted a risk assessment of our supply chain by taking into account:

• The risk profile of individual countries based on reputable sources.
• The nature of services rendered by the suppliers.
• The presence of vulnerable demographic groups.
• Insights from labor and human rights groups.

This assessment determines our response and the risk controls that we implement.

Policies

SoudCoh Pty Ltd operates the following policies for identifying and preventing slavery and human trafficking in our operations:

• Whistleblowing Policy: We encourage all employees, clients, and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation. We protect the identity of whistleblowers, and only specific individuals are aware of the reporter’s identity on a strictly need-to-know basis.
• Code of Conduct: Our code encourages employees to do the right thing by clearly stating the actions and behavior expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behavior when operating and managing our supply chain.
• Purchasing Policy: Our Purchasing Policy makes explicit reference to slavery and human trafficking.

Supplier Due Diligence

SoudCoh Pty Ltd conducts due diligence on all new suppliers and existing suppliers at regular intervals. This includes:

• Assessing risks in the provision of particular services.
• Auditing the suppliers and their health and safety standards, labor relations, and employee contracts.
• Requiring improvements to substandard employment practices.
• Sanctioning suppliers that fail to improve their performance in line with our requirements.

Where possible, we require all suppliers to attest that:

• They don’t use any form of forced, compulsory, or slave labor.
• Their employees work voluntarily and are entitled to leave work.
• They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment.
• They don’t require employees to post a deposit/bond and don’t withhold their salaries for any reasons.
• They don’t require employees to surrender their passports or work permits as a condition of employment.

Exceptions to the above requirements are large companies where SoudCoh Pty Ltd doesn’t have the scale to mandate these requirements (e.g., Microsoft or Google). In these cases, we use news searches and desktop research to identify risks.

Awareness

SoudCoh Pty Ltd continually raises awareness of modern slavery issues through communications with staff, focused specifically on modern slavery and explaining:

• Our commitment in the fight against modern slavery.
• Red flags for potential cases of slavery or human trafficking.
• How employees should report suspicions of modern slavery.

Training

In addition to the awareness program, SoudCoh Pty Ltd requires all managers to complete an e-learning course, which covers:

• Various forms of modern slavery in which people can be held and exploited.
• The size of the problem and the risk to our business.
• 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 within their own business.
• What external help is available for the victims of slavery.
• What terms and guidance should be provided to suppliers in relation to slavery policies and controls.
• What steps SoudCoh Pty Ltd will take if a supplier fails to implement anti-slavery policies or controls.
• An attestation from employees that they will abide by SoudCoh Pty Ltd’s anti-slavery policy.

Measuring How We’re Performing

SoudCoh Pty Ltd has defined key performance indicators and controls to combat modern slavery and human trafficking in our business and supply chain. These include:

• How many senior employees have completed mandatory training?
• How many suppliers have filled out our ethics questionnaire?
• How many suppliers have rolled out an awareness and training program that is equivalent to ours?
• How many reports have been made by our employees that indicate their awareness of and sensitivity to ethical issues?

This statement has been approved by the Director of SoudCoh Pty Ltd.

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