MODERN SLAVERY POLICY

INTRODUCTION & PURPOSE

Electus Recruitment Pty Ltd (“ECR”) is committed to the highest standards of conduct and ethical behaviour in all our business activities, and to promoting and supporting a culture of honest and ethical behaviour, corporate compliance and strong corporate governance.

ECR expects all who have, or seek to have, a business relationship with ECR to familiarise themselves with the Modern Slavery Act 2018 (Cth) (“Modern Slavery Act”) and the applicable ECR policies and procedures and to act in a way which is consistent with its values.

ECR will only do business with ethical suppliers or organisations who fully comply with this policy, or those who are taking verifiable steps towards compliance.

This policy will be used to underpin and inform any statement on slavery and human trafficking that the Company is required to produce further to the transparency in supply chain requirements of the Modern Slavery Act 2018 (Cth).

ECR is dedicated to respecting and supporting the dignity, well-being and human rights of our employees and those who we engage with through our supply chain and our business in general.

Modern slavery breaches the most fundamental freedoms and human rights of individuals. ECR rejects all forms of modern slavery and recognises modern slavery is never acceptable in any of its forms.

This Policy describes modern slavery and the process to follow to ensure modern slavery does not exist in ECR’s operations.

SCOPE

This Policy applies to people working for or on behalf of, or providing services to, ECR in any capacity, including all suppliers, employees, directors, officers, agency workers, contractors, consultants and any other third-party representatives.

DEFINITIONS

What is Modern Slavery?

(a) Modern slavery describes situations where offenders use coercion, threats or deception to exploit victims and undermine their freedom.

(b) Practices which constitute modern slavery can include:

(i) Trafficking which is the recruitment, harbouring and movement of a person by means of coercion, threat, deception, fraud, and abduction for the purposes of exploitation through modern slavery. Exploitation includes;

the prostitution of others or other forms of sexual exploitation
forced labour or services
slavery or practices similar to slavery
servitude, or
the removal of organs.

(ii) Slavery which is where the offender exercises powers of ownership over the victim including:

the power to make the person an object of purchase, and
the power to use their labour in an unrestricted way.

(iii) Servitude which is where the victim’s personal freedom is significantly restricted, and they are not free to stop working or leave their place of work.

(iv) Forced labour which is where the victim is either not free to stop working or not free to leave their place of work.

(v) Debt bondage which is where the victim’s services are pledged as security for a debt (owed by the victim or by another person) and:

the debt is manifestly excessive
the victim’s services are not applied to liquidate the debt, or
the length and nature of the services are not limited and defined.

(vi) Forced marriage which is where:

coercion, threats or deception are used to make a victim marry, or
the victim does not understand or is incapable of understanding the nature and effect of the marriage ceremony.

(vii) Deceptive recruiting for labour or services, which is where the victim is deceived about whether they will be exploited through a type of modern slavery

(i) exploited through slavery or similar practices, including for sexual exploitation

(ii) engaged in hazardous work which may harm their health or safety, or

(iii) used to produce or traffic drugs.

(d) ECR is committed to limiting the risk of modern slavery within its own business, within its supply chains or through any other business relationship.

POLICY

ECR’s response to Modern Slavery:

All employment with ECR is voluntary.

ECR does not use or condone, child or forced labour in any of its operations or sites and works to ensure these practices are not present in its workforce or supply chain.

ECR does not tolerate any form of unacceptable treatment of workers, including but not limited to the exploitation of children, physical punishment or abuse, or involuntary servitude.

ECR abides by all laws and regulations regarding pay practices and the classification of employment according to job level and status.

Where ECR is made aware of modern slavery practices in its own business or within its supply chain, ECR will investigate all claims and if valid, resolve the issue in line with its values and policies.

ECR provides training with the aim of educating employees and contractors on the signs which may indicate modern slavery, due diligence practices for engaging suppliers, auditing existing suppliers and what action an employee or contractor can take if they have a concern in relation to modern slavery.

ECR conducts risk assessments to determine which parts of the business and supply chains are most at risk from modern slavery to ensure focus on those areas.

Supply Chain:

(a) ECR expects its suppliers to have similar values to ECR in relation to modern slavery and human rights.

(b) ECR engages with suppliers to promote and support anti-slavery practices throughout its supply chain.

(c) ECR is committed to introducing anti-slavery obligations in all supplier contracts. As part of their contractual obligations, suppliers will agree to undertake a process which allows ECR to audit the supplier’s ongoing commitment to eradicating modern slavery within its own business and those of its own suppliers.

Any breach will be taken seriously and dealt with on a case-by-case basis.

A breach by an employee may lead to disciplinary action being taken in accordance with ECR’s disciplinary process. Serious breaches may be regarded as gross misconduct and may lead to termination of employment.

A breach by a supplier will also be dealt with on a case-by-case basis. Depending on the behaviour, ECR may exercise contractual remedies, including termination of the relevant contract, or may decide to work with the supplier so they become compliant with legislation and ECR’s values and policies.

Labour Hire providers may be audited at least once during their engagement if contracted for short term requirements. Labour Hire providers used more frequently, or over multiple sites are to be audited at least once each year.

Any person who has reason to believe or has a reasonable suspicion ECR or any of its suppliers are conducting business with an entity which is participating in activities prohibited under this policy and under the Modern Slavery Act must report the suspected activity to their supervisor/manager.

ECR is committed to ensuring it meets the obligations under the Modern Slavery Act and are dedicated to accessing risks and implementing mitigation measures in order to eliminate modern slavery and will continue to develop, communicate and maintain processes including training for employees and contractors, supplier due diligence and statutory reporting.

Communications & Training

ECR Managers will ensure that relevant personnel receive adequate training on this policy and any supporting processes applicable to their role.

Responsibility for This Policy

The ECR Director has overall responsibility for this policy and in ensuring that the ECR complies with all its legal and ethical obligations.

All Managers are responsible for ensuring that personnel comply with the provisions of this policy in the day to day performance of their roles.

Monitoring and Review

This policy and procedure will be reviewed annually by the Director, with corporate staff, client and other stakeholder feedback.

Electus Recruitment’s Continuous Improvement Plan will be used to record and monitor progress of any improvements identified and where relevant feed into service planning and delivery processes.

Annual client satisfaction surveys will assess satisfaction with Electus Recruitment’s governance processes and provide opportunity for feedback on areas for improvement.

Reference

ECR Business Management System Baseline 25 June 2026

All ECR Policies and Procedures.

ECR WHS/BMS Policies and Procedures

ECR Code of Conduct

REVIEW SEQUENCE: ANNUAL.

Document Owner: Fiona Hackett. Original Issue Date: 1st January 2024

Authorised by: ECR Director (Top Management). Fiona Hackett

Date: 25 June 2026