Policy Number: BS-HR-003

Date of First Issue: May 2025

Approved By: Board of Directors

Next Review Date: May 2028

Policy Owner: Chief Executive Officer

Objective

BroadSource is committed to identifying and addressing modern slavery risks across its operations and direct suppliers. Modern slavery includes serious exploitation such as human trafficking, slavery, servitude, forced labour, debt bondage, deceptive recruitment, and child labour.

Under the Modern Slavery Act 2018 (Cth), BroadSource, as an Australian entity with consolidated revenue below the reporting threshold, is not required to prepare nor publish an Annual Modern Slavery Statement.

This policy sets out our approach to meeting the standards set out in the Act and demonstrates our commitment to ethical sourcing and human rights protections.

BroadSource’s Structure, Operations and Supply Chains

Structure
BroadSource is an Australian-headquartered software development and cloud service provider operating globally. The company delivers telecommunications software and managed services to enterprise clients, system integrators, and telcos in Australia, Asia, Europe and the Americas.

Operations and Supply Chains
BroadSource employs staff across Australia, Europe and the UK, and its operations include software development, cloud services, customer support, and professional services.

BroadSource’s supply chain includes:

1. Cloud infrastructure providers
2. Software development tools and platforms
3. Professional services (legal, consulting, marketing)
4. Global contractors and consultants

While BroadSource’s core operations are in Australia and in the technology sector—which is considered lower-risk—certain suppliers, especially in offshore jurisdictions or industries such as electronics manufacturing, may pose a higher risk of modern slavery.

Management of Modern Slavery Risk

BroadSource uses a risk-based approach to identify and address modern slavery risk in its supply chain.

Measures include:

1. Avoiding engaging with high-risk suppliers from high-risk sectors in high-risk geographies
2. Selecting tier 1 service providers with an up to date statement on the Modern Slavery Statements Register (or equivalents for overseas suppliers)
3. Advise key suppliers and contractors that BroadSource expects:
   1. Compliance with modern slavery laws
   2. ability to provide evidence of ethical sourcing and labour practices
   3. Notification of any breaches or incidents
   4. Requiring key vendors and partners to complete modern slavery due diligence questionnaires
   5. Monitoring supplier relationships and, where needed, terminating contracts in response to non-compliance

Roles & Responsibilities

Responsibility
The Chief Executive Officer (CEO) is responsible for overseeing the implementation and maintenance of this policy. BroadSource’s executive team and procurement function are responsible for day-to-day compliance and supplier engagement.

The policy will be reviewed every three years, or earlier if legal or operational changes warrant.

Reporting Concerns
Employees, contractors, and suppliers are encouraged to report any suspicion of modern slavery, either:

1. Via email to: legal@broadsource.com.au

2. Or directly to the CEO

All reports will be treated confidentially and investigated appropriately.

Handling Reports and Remediation
Where a report is substantiated, BroadSource will engage with affected suppliers and stakeholders to:

1. Cease contributing to harm
2. Mitigate further risk
3. Support remediation pathways, including support for affected individuals, where appropriate

Related Documents

1. Code of Conduct
2. Supplier Onboarding Guidelines
3. Procurement and Vendor Management Policy

Interpretation and Access

This policy aligns with Australian federal legislation and international human rights conventions. It is reviewed and interpreted in line with advice from the Attorney-General’s Department and industry best practices.

The current version of this policy is available on the BroadSource website and internal document portals.

Accessibility

BroadSource is committed to making this policy accessible to all employees and suppliers. It is distributed as part of the supplier onboarding pack and included in internal staff training and onboarding.