Modern Slavery Policy.

Effective Date: 09/09/2025

This policy establishes the framework for PRIDESTATE to identify, assess, and address the risks of modern slavery and human trafficking in its operations and supply chains. The provisions of this policy are legally binding on all directors, management, employees, contractors, and partners, and are designed to ensure full compliance with the Commonwealth’s modern slavery legislative regime.

1. Policy Objectives.

The core objectives of this policy are to:

Prohibit all forms of modern slavery and human trafficking within the Company’s business and its sphere of influence.
Implement a robust due diligence process to identify, mitigate, and report modern slavery risks across all supply chains.
Raise awareness among all stakeholders, including contractors and partners, about the signs of modern slavery and the procedures for reporting concerns.
Ensure the Company’s compliance with its reporting obligations under the relevant legislation.

2. Legal and Regulatory Framework.

This policy has been developed in accordance with the following key legislative and international instruments:

Modern Slavery Act 2018 (Cth): This is the primary piece of Australian legislation that requires certain entities to report annually on the risks of modern slavery in their operations and supply chains, as well as the actions they have taken to address those risks.
The United Nations Guiding Principles on Business and Human Rights provide the international benchmark for the Company’s responsibility to respect human rights, including its duty to conduct human rights due diligence and to provide for or cooperate in remediation where it causes or contributes to adverse human rights impacts.

3. Key Obligations.

3.1 Risk Assessment and Due Diligence

PRIDESTATE shall undertake a proactive and ongoing risk assessment of its operations and supply chains to identify potential modern slavery risks. This includes, but is not limited to:

Supplier and Partner Vetting: The Company will conduct due diligence on new and existing contractors and partners to assess their commitment to preventing modern slavery. This may include contractual clauses, questionnaires, and third-party audits.
Geographical and Sectoral Risk: The Company will pay particular attention to geographical areas and industries known to have a higher risk of modern slavery, such as specific sectors within the construction and cleaning services industries.

3.2 Remediation and Grievance Mechanisms

The Company is committed to providing access to effective grievance mechanisms for any individual who believes they have been subject to or have witnessed modern slavery. This includes:

Confidential Reporting: The establishment of confidential reporting channels for all personnel, contractors, and partners to raise concerns without fear of reprisal.
Remediation: If modern slavery is identified, the Company will take immediate and appropriate action to address the situation, including working with the relevant authorities and providing support to affected individuals.

3.3 Reporting Obligations

The Company will prepare and submit an annual Modern Slavery Statement in compliance with the Modern Slavery Act 2018 (Cth). This statement will detail the actions taken during the reporting period to assess and address modern slavery risks.

4. Application to Contractors and Partners.

This policy extends to all individuals and entities acting as contractors or partners of PRIDESTATE. Your obligations are as follows:

Compliance: You are required to comply with all aspects of this policy fully and to assist the Company in its efforts to prevent and address modern slavery.
Disclosure: You must provide complete and accurate information about your own supply chains and due diligence processes when requested by the Company.
Reporting: You must immediately report any instance of modern slavery you become aware of to the Company’s designated Compliance Officer.

5. Roles and Responsibilities.

Board of Directors: The Board bears ultimate responsibility for overseeing and approving the Modern Slavery Statement and the Company’s overall approach to preventing modern slavery.
Compliance Officer: This designated individual is responsible for the day-to-day implementation of this policy, including conducting risk assessments, managing grievance mechanisms, and coordinating the annual reporting process.
All Personnel, Contractors, and Partners: Each individual is personally responsible for understanding and adhering to this policy and for remaining vigilant to the risks of modern slavery.

6. Non-Compliance.

Failure to adhere to the provisions of this policy is considered a serious breach of professional and ethical duties. Such non-compliance may lead to the termination of contracts or partnerships and, where applicable, may result in criminal prosecution under relevant human trafficking and slavery legislation.

7. Policy Review.

This policy shall be reviewed on an annual basis or as required by a material change in legislation or business operations.