MODERN SLAVERY POLICY
Purpose
This Modern Slavery Policy (Policy) has been prepared in accordance with the Modern Slavery Act 2018 (Cth) (the Act) and is issued on behalf of PMY Group Pty Ltd and its subsidiaries (PMY). Given PMY’s global reach, it has also considered the requirements of the Modern Slavery Act 2015 (UK) and other relevant legislation in preparing this Policy.
PMY has always been committed to conducting its business in a moral and ethical way. It understands and recognises the need to put governance policies and business practices in place which not only reflect PMY’s core values but also comply with relevant legal and regulatory frameworks.
As such, PMY has put together this Policy so it can hold itself accountable and continuously improve its business practices by addressing potential risks. By implementing and enforcing effective systems and controls throughout its organisation and supply chains, PMY can uphold the standards it places on itself as well as regulatory requirements in its sector.
Application
This Policy applies to employees (whether full-time, part-time or casual), directors, officers and contractors of PMY. Any business partner, vendor, supplier or subcontractor must agree to this Policy and uphold the same standards within their organisation.
If this Policy is not complied with, PMY may end its business relationship with you and, if you are an employee, it may impact your employment at PMY.
What is Modern Slavery?
Modern Slavery is an umbrella term that is used to describe human trafficking, slavery, servitude and forced labour. These acts involve situations where offenders use coercion, threats or deception to exploit victims and undermine their freedom.
Modern Slavery can take many forms, including:
- Slavery – owning a person, trading in slaves or financing slave trading (i.e., human trafficking).
- Forced labour – forcing a person to work by coercion or threats (and servitude is when that person’s freedom is significantly restricted).
- Forced marriage – a marriage without free and full consent (e.g., due to lack of understanding or duress/coercion).
- Debt bondage – a person works to pay off a large debt, for an unlimited time or where the value of the work is not applied to the debt.
- Deceptive recruiting – a recruiter charges a fee for the job offer, confiscates identity documents, deceives a person about personal freedom or their ability to leave the job.
- Child labour – not always unlawful but not tolerated by us when it involves exploiting children, depriving them of education, or making them work in unsafe working environments.
Modern Slavery can be complex and multi-faceted and difficult to spot, which is why it is so important to be vigilant.
PMY does not condone or partake in any of these acts.
What should I look for?
Anyone can be a victim of Modern Slavery. However, some groups are more vulnerable than others. These can include, backpackers, international students, people seeking asylum and migrants who are on limited working visas or who may not have the relevant knowledge of their rights in the relevant country.
Modern Slavery indicators may include where a person:
- is not in possession of their own passport, ID or travel documents;
- is acting as though they are being instructed or coached by someone else;
- allows others to speak for them when spoken to directly;
- is dropped off and collected from work;
- is withdrawn, appears frightened or has physical indicators of slavery, such as injuries;
- is unable to contact friends or family freely;
- has limited social interaction or contact with people outside their immediate environment;
- has a story that contains obvious errors;
- acts with hostility or has difficulty in concentrating due to trauma;
- has few possessions;
- has little or no control over their finances or no access to a bank account, or they are being significantly overcharged for their accommodation;
- has excessive hours of work;
- is isolated, either geographically, socially and/or linguistically; and/or
- is living in a very poorly maintained and overcrowded place, or at the workplace or another place controlled by their employer.
These indicators do not necessarily mean that Modern Slavery practices are taking place, but it is good to look out for these indicators and the circumstances surrounding them.
Why do we want to limit the risk of Modern Slavery?
Apart from being a good business practice, it is important to protect the rights of all people and our reputation. PMY prides itself on being an ethical and moral employer and business partner.
In trying to limit the risk of Modern Slavery, we can look at our own practices and consistently better ourselves.
What are our goals?
PMY will endeavour to:
- identify and address Modern Slavery risks in its business and supply chain;
- prepare a Modern Slavery Statement as required by law; and
- take steps to raise awareness of Modern Slavery risks within its organisation, including by having this Policy and annual training.
What are your responsibilities?
As an employee or contractor of PMY, you must take all reasonable steps to ensure our business is not engaging in Modern Slavery practices.
If you are a business partner of PMY, you must ensure that your organisation, along with your supply chains, are free from Modern Slavery practices and you can comply with the Act and/or any other applicable legislation.
Turning a blind eye is unacceptable, and if you reasonably suspect that there may be Modern Slavery practices within or involved with PMY you must report it under this Policy.
How do I report Modern Slavery concerns?
If you have a reasonably held suspicion of Modern Slavery practices, you should discuss your concerns with your manager, who will then escalate to the Chief Executive Officer and General Counsel. They will assess the situation and provide any further advice.
If there is immediate danger, call the police. Don’t tackle a situation on your own as dangerous criminals can be behind these practices.
It is important to remember that not all victims of Modern Slavery will take assistance. Sometimes, reporting a suspected behaviour can put the victim at further risk. This is why it is so important for you to raise your concern with your manager first, unless the victim is in immediate danger.
Keep your eyes and ears open, your awareness and actions may stop someone from being exploited or abused.
Review
This Policy will be kept up to date, particularly as the business changes in nature and size. To ensure this, the Policy and the way in which it has been implemented will be reviewed annually.
Last updated: December 2025