Modern Slavery Policy
1.0 Policy Overview
WithYouWithMe (WYWM) is committed to conducting business responsibly and ethically, respecting internationally recognised human rights, and taking reasonable steps to identify, assess and address risks of modern slavery within our operations and supply chains.
This policy supports WYWM's compliance with applicable modern slavery and human rights requirements in the jurisdictions in which we operate, including the Modern Slavery Act 2018 (Cth) (Australia) and the Modern Slavery Act 2015 (UK), where applicable, and is informed by the UN Guiding Principles on Business and Human Rights.
WYWM applies a risk-based approach to modern slavery prevention, supplier due diligence, reporting and remediation
2.0 Definitions
Modern slavery encompasses various severe forms of exploitation, including:
- Slavery: The exercise of ownership over a person.
- Servitude: The obligation to provide services is imposed through coercion.
- Forced or compulsory labour: Work or service performed involuntarily and under the threat of force or penalty.
- Human trafficking: Arranging or facilitating the travel of another person with the intent to exploit them.
These forms of exploitation all involve one party depriving another of their freedom to exploit them for personal or commercial gain.
3.0 Signs of Modern Slavery
Modern slavery can be difficult to detect. However, potential signs might include:
- Evident restriction of movement, travel, or confinement to a specific area.
- Fearful, anxious, or submissive behaviour, especially in the presence of others.
- Discrepancies between the job being performed, the working conditions, and what their contract states.
- The inability to produce identity or travel documents, or these documents being held by someone else.
- Inability or unwillingness to give an address or details about who they live with.
4.0 Policy Implementation
The VP Operations is the owner of this policy and is responsible for overseeing WYWM’s approach to modern slavery risk, including policy maintenance, personnel awareness, supplier risk oversight, receipt of reported concerns, and escalation of material matters.
Personnel responsible for engaging or managing suppliers must consider modern slavery risk as part of supplier selection, due diligence and ongoing supplier management, in accordance with WYWM’s risk-based supplier management processes.
All WYWM personnel are responsible for complying with this policy, remaining alert to indicators of modern slavery, and reporting suspected concerns through the reporting channels set out in this policy.
The CEO provides executive oversight of material modern slavery risks, incidents and remediation where escalation is required.
5.0 Risk Based Approach
WYWM applies a risk-based approach to identifying and managing modern slavery risks within its operations and supply chains.
Modern slavery risk may be considered as part of supplier onboarding, supplier risk assessment and ongoing supplier review, taking into account factors such as the nature of the goods or services provided, geographic location, industry, labour practices, use of subcontractors and other relevant risk indicators.
Suppliers assessed as presenting elevated modern slavery risk may be subject to additional due diligence, evidence requests, contractual controls, remediation requirements or other proportionate risk treatment.
The level and frequency of ongoing monitoring will be proportionate to the supplier's assessed risk.
6.0 Employee Expectations
All WYWM personnel are expected to remain vigilant and report any reasonable suspicion of modern slavery within WYWM's operations, supply chains or business relationships. Personnel are encouraged to raise concerns even where they are uncertain. Reasonable suspicion does not require definitive proof, but should be based on reasonable grounds that modern slavery may be occurring.
7.0 Reporting Mechanisms
We promote an environment of openness within our company. We encourage all our staff, customers, and other business partners to voice any concerns related to possible breaches of this policy in our direct activities or supply chains.
8.0 Reporting Process for Modern Slavery Concerns
8.1 Channels for Reporting
Concerns may be reported confidentially to people.culture@withyouwithme.com, which is managed by the VP Operations. External parties may also raise concerns through their WYWM Account Manager, who must escalate the matter to the VP Operations.
8.2 Process for Reporting
Any individual who suspects instances of modern slavery in any part of our operations or supply chain should report it immediately using any of the above channels.
The report should include, where possible, details about the nature of the suspected slavery, the individuals involved, and any other relevant information that could assist in an investigation.
8.3 Response to Reports
All reports will be taken seriously and assessed by the VP Operations. Where appropriate, the VP Operations may involve the CEO, relevant personnel, external advisers, authorities or specialist services in the assessment or investigation of a concern. Information relating to a report will be handled confidentially and disclosed only where reasonably necessary or required by law.
8.4 Protection for Whistleblowers
We are committed to ensuring that no individual suffers any detrimental treatment as a result of reporting a suspicion of modern slavery in good faith. Retaliation against employees or other individuals who have reported concerns in good faith is strictly prohibited.
8.5 Follow-Up and Feedback
We will provide feedback to the individual who raised the concern, where appropriate and possible, regarding the outcome of any investigation. If required, we will take appropriate action against individuals or organisations found to be involved in modern slavery.
8.6 Training and Awareness
WYWM will provide modern slavery awareness and training proportionate to personnel roles and responsibilities. Personnel involved in supplier engagement, supplier management or other activities presenting elevated modern slavery risk may receive additional guidance or training where appropriate.
8.7 Record Keeping
A record of concerns reported under this policy, and any resulting assessment, investigation, escalation or remediation, will be maintained securely and confidentially, where appropriate.
8.8 Continuous Improvement
The effectiveness of WYWM's reporting arrangements will be considered as part of the annual policy review and following any material modern slavery concern or identified control weakness.
9.0 Supplier Selection and Due Diligence
9.1 Supplier Assessment Criteria
Suppliers are assessed on their commitment to human rights and anti-slavery principles. This includes evaluating their policies, practices, and track record in these areas. We prioritise suppliers who have clear, enforceable policies against modern slavery and human trafficking.
9.2 Due Diligence Process
Modern slavery due diligence will be proportionate to the nature and level of risk associated with the supplier. Where warranted by the supplier's risk profile, due diligence may include:
- reviewing relevant human rights or modern slavery policies and commitments;
- assessing labour practices, workforce arrangements and use of subcontractors;
- reviewing publicly available information concerning material allegations or enforcement action;
- obtaining relevant supplier declarations, certifications or supporting evidence; and
- conducting enhanced due diligence or seeking further assurance where elevated risk is identified.
9.3 Supplier Agreements
Where proportionate to the nature and risk of the engagement, WYWM may include contractual requirements relating to compliance with applicable modern slavery, human rights and labour laws. Higher-risk suppliers may also be required to maintain appropriate controls within their own supply chains and provide evidence of compliance when reasonably requested by WYWM.
9.4 Ongoing Monitoring and Evaluation
Ongoing supplier monitoring will be proportionate to the supplier's assessed modern slavery risk. Monitoring may include review of relevant certifications or supporting evidence, direct engagement with the supplier, reassessment of risk, or other appropriate assurance activities.
Where a supplier is identified as presenting unacceptable modern slavery risk or is found to have materially breached applicable requirements, WYWM will determine appropriate risk treatment. This may include seeking further information, requiring remediation, applying additional controls, suspending engagement or terminating the business relationship.
10.0 Policy Review
This policy will be reviewed at least annually and following material changes to applicable legal requirements, WYWM's operations or supply chain, or where a material modern slavery risk or control weakness is identified. The policy will be updated where necessary to maintain its relevance and effectiveness.
Date last reviewed: 15 September 2026
Approved by: VP Operations
Next review due: 15 September 2027
