Modern Slavery Policy

Introduction

Cyber Sense is committed to preventing Modern Slavery in all its forms, including forced labour, child labour, and human trafficking, within our operations and supply chains. This Policy is designed in accordance with the Modern Slavery Act 2018 (Cth), as well as other applicable laws, and reflects our commitment to uphold human rights and ethical business practices.

As a cybersecurity consultancy, Cyber Sense recognizes the risks of Modern Slavery within the tech sector and related service industries and remains dedicated to ensuring business activities are completely free from any involvement in Modern Slavery. We continuously engage with stakeholders to effectively mitigate these risks.

Application of the Policy

This Policy applies to all employees, contractors, officers, and directors of Cyber Sense. It also encompasses all subsidiaries, affiliates, suppliers, and third parties that provide goods or services to Cyber Sense. Upholding this Policy is a critical part of our ethical business practice commitment and applies to all business operations, covering recruitment, employment practices, and all interactions with suppliers and third parties.[1]

Reporting Entities Covered by the Policy

This Policy applies to Cyber Sense and any directly or indirectly related entities, as well as all personnel and external service providers involved in our operations or business relationships. Any reference in this Policy to Cyber Sense pertains to the company and its affiliates individually and collectively.

What is Modern Slavery?

‘Modern Slavery’ refers to the serious exploitation of individuals for personal or commercial gain, including practices such as human trafficking, slavery, servitude, forced labour, debt bondage, forced marriage, child labour, and deceptive recruitment. Modern Slavery encompasses any scenario where individuals are forced to work or provide services against their will through coercion, threats, or deception.

Responsibility for the Policy

Responsibility for implementing and enforcing this Policy lies ultimately with the Cyber Sense Board of Directors. Day-to-day oversight of compliance rests with our General Counsel (or equivalent) in conjunction with our internal Modern Slavery Committee, which monitors and addresses Modern Slavery risks. Managers and leaders at all levels are responsible for Policy adherence within their teams. All employees must comply with the principles of this Policy and participate in relevant training and awareness programs.

Compliance with the Policy

All employees, contractors, suppliers, and business partners must comply with the principles of this Policy. Non-compliance may result in disciplinary action, including termination of employment, contracts, or business relationships, according to the severity of the breach. Cyber Sense manages risk and compliance through:

  • Annual training and awareness programs on Modern Slavery risks for staff and key stakeholders.
  • Internal audits to identify areas of concern or non-compliance within our operations and supply chains.
  • Ongoing risk assessments, especially in high-risk regions and sectors.
  • Collaboration with suppliers and contractors to ensure alignment with ethical standards and Policy compliance.

Communication and Awareness

Cyber Sense will ensure widespread communication of this Policy to employees, contractors, suppliers, and partners. Communication measures include:

  • Distribution of the Policy during onboarding for all new staff and contractors.
  • Internal communications, including training sessions, to raise awareness of Modern Slavery risks and our commitment to preventing such practices.
  • Making the Policy accessible via the company’s internal portal and, where relevant, on external websites.
  • Ensuring that suppliers and partners are informed of the Policy and their obligations under it.

Breaches of the Policy

Any breach of this Policy is treated seriously and will be investigated thoroughly by the Committee, with support from the General Counsel. Examples of breaches include:

  • Direct or indirect involvement in Modern Slavery practices (forced labour, child labour, human trafficking, etc.).
  • Utilizing recruiters/agents who do not comply with local labour laws or who charge recruitment fees.
  • Failing to report known or suspected cases of Modern Slavery in Cyber Sense or direct supply chains.
  • Not complying with processes to mitigate Modern Slavery risks (such as inadequate due diligence or risk assessments).

Actions taken may include investigation, corrective training, mitigation steps, or termination of employment/business relationships in severe or repeated non-compliance cases. Reports will be handled confidentially, and staff can safely raise concerns without fear of retaliation.

Reporting

Suspected or actual instances of Modern Slavery should be reported directly to the Cyber Sense Legal Team. Alternatively, employees can use any independent whistleblowing service engaged by Cyber Sense for confidential reporting. Contact information for reporting will be made readily available to all stakeholders.

Review

This Policy will be reviewed annually by the Committee, with final approval from the General Counsel. The review process checks the effectiveness of controls and training programs and ensures alignment with legal, regulatory, and ethical standards. Regular assessments will incorporate feedback, regulatory changes, and industry best practices, with updates made as necessary.