Modern Slavery Policy

1. Purpose

At Next Step Medical Pty Ltd (Business), we are committed to operating in a manner that identifies, prevents, and mitigates modern slavery risks across our operations and supply chains.

This policy:

· Outlines our responsibilities under the Australian Modern Slavery Act 2018 (Cth) (the Act);

· Shows how we will address modern slavery risks; and

· Applies whether or not the Business meets the mandatory reporting threshold under the Act.

 

Definitions used in this Policy

· Large business – A large entity meeting the $100 million consolidated revenue threshold set out in the Act, noting compliance for a large business includes submitting annual Modern Slavery Statements.

· Small business – All other businesses, noting that while not legally required to report, are encouraged to adopt the principles within this policy to align with best practices and ethical standards.

2. Scope

This policy:

· Applies to all employees, contractors, suppliers, customers, and visitors of the Business and includes all work-related activities and events conducted by the Business with these parties; and

· covers domestic and international operations by the Business, extending to all entities over which the Business has operational control.

3. Modern Slavery Statement

Modern Slavery in Australia is defined in the Act. Where there are inconsistencies with that definition in the Act and this Policy, the definition in the Act takes precedence.

Modern slavery refers to extreme forms of exploitation including coercion, deception or threats are used to deprive a person of their freedom. It includes but not limited to the following eight types:

· Trafficking persons;

· Slavery;

· Servitude;

· Forced labour;

· Forced marriage;

· Debt bondage;

· Deceptive recruitment for labour or services; and

· The worst forms of child labour where children are subjected to slavery or similar practices engaged in hazardous work.

 

Modern Slavery does not include practices like substandard working conditions or underpayment of workers, notwithstanding that these practices are also harmful and may also be present in some cases of modern slavery.

4. Our Commitment

To combat modern slavery and move toward eradicating it, our business pledges to:

· Adopt ethical business practices, regardless of reporting thresholds;

· Implement due diligence processes in procurement and contracting to minimise the risk in our Business and supply chains;

· Ensure that management establishes a culture of zero tolerance toward modern slavery and human trafficking within the Business

· Implement prohibitions against the use of forced, compulsory or trafficked labour or of anyone held in slavery or servitude;

· Hold our suppliers and contractors to the same standards; and

· Consult and work collaboratively with our Staff Members and Business partners to fulfill these principles.

· Where our business is a large business, conduct annual risk assessments and monitor supplier compliance and provide training.

5. Reporting and Escalation Procedures

Internal Reporting:

All Staff Members and stakeholders are encouraged to report any suspicions, actual or suspected cases of modern slavery within our operations or supply chains.

Reports will be investigated promptly and appropriate remedial action will be taken in accordance with applicable laws and regulations, including the Act.

Reports can be made confidentially to the General Manager and/or designated Compliance Officer.

 

External Reporting:

In Australia – Contact the Australian Federal Police (AFP) at 131 237 or NOSSC-Client-Liaison@afp.gov.au.

For international cases – Report to the Australian Border Force at slavery.consultations@abf.gov.au.

Immediate Danger – If someone is at immediate risk in Australia, call 000 (Police).

6. Non-Compliance and Disciplinary Measures

Conduct which breaches this policy is unacceptable.

Depending on the severity and circumstances, breaches of this policy may lead to:

· The requirement to provide an apology (written or verbal);

· A formal warning;

· A performance improvement plan;

· A requirement to attend training and/or counselling;

· Dismissal; and

· For suppliers or contractors who fail to meet modern slavery standards, termination of contract.

7. Effective Date

This policy is effective as of 20th January 2025 and shall be formally reviewed annually and updated in consultation with internal and external stakeholders, ensuring alignment with any legislative amendments.

8. Authorisation

Name: Charles Safapour

Position: CEO