Purpose

ASPL Group is committed to respecting and supporting thedignity, well-being, and human rights of all people. We are dedicated topreventing modern slavery and human trafficking within our operations andsupply chains, consistent with our values of integrity, inclusion, and socialresponsibility.

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This policy sets out ASPL Group’s approach to identifying, preventing, and addressing modern slavery risks, in line with the ModernSlavery Act 2018 (Cth).

Scope

This policy applies to all ASPL Group employees, contractors, consultants, suppliers, and partners, across all operations inAustralia and internationally.

Definition

Modern slavery involves serious exploitation and includes:

• Slavery, servitude, and forced labour.
• Human trafficking.
• Debt bondage.
• Deceptive recruiting for labour or services.
• Forced marriage (where relevant in supply chains).

ASPL Group Commitment to Anti-slavery

• Operate with integrity and ethical practice in all business dealings.
• Undertake annual Modern Slavery risk assessments of operations and supply chains.
• Apply ASPL’s Modern Slavery Supplier Code of Conduct, requiring suppliers to uphold human rights and ethical labour practices.
• Engage suppliers transparently where risks are identified, developing action plans to remediate issues. If a supplier is unwilling to cooperate, ASPL will take appropriate action, up to and including termination of the business relationship.
• Publish an annual Modern Slavery Statement in compliance with the Modern Slavery Act 2018 (Cth).

Governance & Responsibilities

• CEO: Holds overall accountability for compliance with this policy.
• Risk & Quality Manager: Oversees implementation, monitoring, and reporting.
• Managers & Employees: Responsible for applying this policy in procurement, operations, and daily activities.

Supply Chain Due Diligence

ASPL undertakes the following steps to manage modern slavery risks in its supply chains:

• Supplier screening and risk assessments during onboarding.
• Supplier questionnaires/checklists for higher-risk industries.
• Periodic monitoring and review of supplier compliance with the Supplier Code of Conduct.
• Immediate escalation of concerns to ASPL’s governance team.

Reporting & Whistleblowing

• Suspected instances of modern slavery can be reported to line managers, the Risk & Quality Manager, or the CEO.
• Anonymous reporting is available via ASPL’s Whistleblower Policy.
• All reports will be investigated promptly and addressed transparently.

Training & Awareness

ASPL will provide training to employees, contractors, and procurement staff on:

• Recognising the signs of modern slavery.
• Reporting obligations and processes.
• Supplier due diligence expectations.

Monitoring & Continuous Improvement

ASPL measures the effectiveness of this policy through:

• Annual supplier compliance reviews.
• Internal audits of procurement processes.
• Stakeholder feedback and staff training completion rates.
• Lessons learned following incidents or reviews.

This policy will be reviewed annually to ensure its ongoing effectiveness and alignment with legislation and best practice.

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