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Anti-Modern Slavery Statement

Introduction
Safe365 opposes all forms of modern slavery practices and is committed to eradicating these practices from our own operations and supply chains. Modern slavery can take many forms, and even in Australia, New Zealand and other countries in which we operate, modern slavery still exists. Some of its forms include forced or compulsory labour, servitude, trafficking in persons, debt bondage, forced marriage, forced prison labour and child labour. We are committed to identifying, preventing, mitigating and remediating modern slavery impacts connected to our business.

We recognise that as a purchaser and supplier of a diverse range of products and services, we must embed appropriate practices in our business and seek to work with suppliers who are aligned with our values. In this statement, we set out the actions Safe365 has taken to recognise and minimise the risk of modern slavery in our business operations and supply chain. For the avoidance of doubt, ‘Safe365’ includes Safe365 Limited, as well as Safe365 Global (Australia) PTY LTD, and Safe365 Global (UK) Limited.

Our structure, operations and supply chains
Safe365 works with organisations and communities around the world to solve their biggest work health, safety & wellbeing challenges, imagine new possibilities, and help move them to a better place by connecting people and technology. Safe365 is on a mission to proactively reduce harm globally with a goal of having 100 Million workers covered by a proactive risk environment. Through our solutions, we change cultures and ways of valuing risk across organisations, helping them to improve their safety leadership, address lead risk indicators, and ultimately improve health and wellbeing outcomes and reduce harm in the workforce.

Built on strong local values, world-class technology, and experienced people who genuinely care, Safe365 sets a new standard in SaaS and PaaS services. Safe365 supports customers through a broad range of services and solutions, all underpinned by robust industry experience and insight. Safe365 has 30 people working across Australia, New Zealand, South America and Asia. Safe365 is truly world-class in capability, and proudly local at heart.

Safe365 has a wide range of services and products including professional and technology management services, integrated SaaS & PaaS solutions, software reselling, and customer contact operations. The majority of Safe365 businesses operate in Australia, New Zealand and the United Kingdom, with some technical operations in India. Further information about Safe365 can be found on our website www.safe365global.com.

We work with a range of suppliers globally. Our suppliers are generally large global providers of SaaS based business applications that are used to support our customer solutions or the conduct of our business operations. Our suppliers are mainly based in New Zealand, Asia and the United States of America.

Our relationships include suppliers from the following sectors: technology, hardware and equipment, facilities management, office supplies, catering, cleaning, ICT labour hire, professional services and marketing. We use these products and services in our business, and we also operate as a reseller of products and services, such as software solutions from our partners that complement Safe365’s solutions.

 

Potential modern slavery risks
Our initial risk assessment and prioritisation of work focussed on the aspects we considered to be higher risk, and to coincide with a broader programme of work, we had commenced to improve and consolidate our procurement practices generally within Safe365. This has also been part of our ongoing integrated management system (IMS) work which underpins our ISO9001 (Quality Management), ISO45001 (Occupational Health and Safety Management) and ISO14001 (Environmental Management) certifications, and our alignment to ISO 27001 (Information Security). We have also paid greater attention to the modern slavery risks that would cause the greatest harm to individuals.

 

Internal Operations:
Our risk assessment identified that we have a lower risk of modern slavery. As a part of this assessment, we paid particular attention to areas that could be considered to be higher risk such as operations outside New Zealand, Australia and the UK, undertaken by businesses within the wider Safe365 group, recruitment practices and temporary workforce arrangements.

The majority of our workforce are permanent employees and would be considered to be in the higher skill and lower risk brackets. Our employees are employed on contracts with standard terms allowing the employee to terminate their employment on notice and all employees are paid at or above the relevant minimum wage. From time to time, we may have blocks of temporary workers for “surge” resourcing purposes. In these cases, recruitment companies at the “high end” of reputability are utilised to employ these workers, who we then induct, train and manage.

Finally, in our supply chain, we have only a few individual contracted workers. These are largely individuals with specialised skills or experience and are engaged as professional contractors. We also recognise that some of Safe365’s supplier operations in countries outside New Zealand and Australia are located in known higher-risk geographies. While these operations are not controlled entities of Safe365, the services they provide are used by Safe365. To address the geographic risk, we have performed a high-level review of the operational practices of our New Zealand-based provider of this workforce and consulted with them to explain and help identify any potential modern slavery risks. This included considering and reviewing processes and systems and conducting interviews and discussions with key representatives.We have also assessed the suppliers to our operations and will prioritise working with these suppliers further according to the higher risk categories we identified as a part of the general supply chain review and procurement consolidation process we are undertaking at Safe365.

 

Supply Chain:
For our supply chain, as a result of our supplier risk assessment outlined above, we identified very low risk suppliers through to those within a potentially high-risk category. In the higher-risk category, we identified suppliers of technology products and services (for both internal use and on-supply or resale to customers), cleaning, maintenance services, freight, catering, office supplies, temporary workforce suppliers and marketing products and services. Of course, as this supplier risk assessment was primarily focused on industry and function, there is still more work for us to do to dive deeper into our major suppliers to look at specific geographies and actual practices of the specific suppliers.

We also understand that our suppliers have their own suppliers, which may also connect us to modern slavery risk. We do not currently have a detailed understanding of this risk beyond our first-tier suppliers. We are aware, however, of some industry risks that will be in the lower tiers of our supply chain.

We intend to prioritise our supplier engagement activities according to those higher-risk categories over 2025/2026. We also intend to target a prioritised engagement programme and an on-boarding process to apply to all new suppliers to give us a better understanding of supplier-related modern slavery risks while also making our expectations clear to our suppliers in respect to suppliers ensuring proactive awareness and effort to identify and eliminate modern slavery risks in their supply chains.

Our Whistleblower Policy (IMS-P-065) specifically recognises the risk of modern slavery and encourages our employees, contractors and suppliers to report and act on any modern slavery concerns. Where concerns are investigated and substantiated, we are committed to taking appropriate action. Further information regarding the investigation process is available on request.

 

Action to assess and address modern slavery risks

Our planned actions for 2025/2026 include:

  • Continue with our modern slavery risk assessment.
  • Commence implementing anti-modern slavery commitments into our supplier contracts.

 

Assessment of our effectiveness

To date, we believe that we have effectively established the initial foundation to assess and mitigate the risks of modern slavery in our internal operations and supply chain, and have initiated the process of raising awareness on this important topic. There is still much to be done as our business grows, our policies become more embedded, and our people increase their awareness to support Safe365’s commitment to anti-modern slavery collectively.

We intend to continue with our actions listed above and, importantly, continue to educate and train our business teams so they are alert to the risks. Most importantly, we recognise this is not a static programme. We will adopt a process of continuous improvement, assessing whether processes are up-to-date and effective, and will endeavour to focus on areas with the highest potential impact on people.

We also note that modern slavery policy statements are not a legal requirement in New Zealand. This statement and Safe365’s commitment to anti-modern slavery is made voluntarily because it aligns with our values as a business, because we understand it is important to some of our clients whom we undertake business with globally and because we can assist with increasing market awareness of this issue in our society so that generally more can be done to eliminate modern slavery.