1.Purpose

This Modern Slavery Policy (Policy) sets out Checkbox’s commitments, expectations and the controls it applies to identify, assess, prevent, mitigate and remediate the risk of Modern Slavery and Human Trafficking in its operations and supply chains. Modern Slavery is a serious crime and a violation of fundamental human rights, and Checkbox is committed to conducting its business ethically, with integrity and in preventing it.

1.1Policy protections

This Policy protects:

• the Workers in Checkbox’s operations and supply chains from Slavery, Servitude, Forced or Compulsory Labour, Debt Bondage, Human Trafficking and the worst forms of Child Labour;
• the fundamental human rights and dignity of the individuals and Workers connected to Checkbox’s business;
• the integrity of Checkbox’s operations, procurement and supply chains; and
• Checkbox’s compliance with Modern Slavery, anti-trafficking and forced-labour laws, and the trust of its customers, regulators and business partners.

1.2Policy objectives

Checkbox has a zero-tolerance approach to Modern Slavery. In particular, Checkbox commits to:

• comply with all applicable Modern Slavery, anti-trafficking, Forced and Compulsory Labour and related human rights laws in the jurisdictions in which it operates;
• prohibit the use of any form of Slavery, Servitude, Forced or Compulsory Labour, Debt Bondage, Human Trafficking or Child Labour in its operations;
• identify and assess Modern Slavery risks in its operations and supply chains, and take reasonable and proportionate steps to address those risks;
• conduct risk-based due diligence on Suppliers;
• provide accessible channels through which Personnel and third parties can raise concerns, without fear of retaliation;
• remediate adverse impacts that it has caused or contributed to, and use its leverage to address impacts directly linked to its operations, products or services;
• encourage Personnel to recognise and respond to Modern Slavery risks; and
• monitor the effectiveness of these measures and continuously improve them, and report transparently as required by law.

2.Scope and application

2.1Scope

This Policy applies to all entities within the Checkbox Group, including all Personnel. Checkbox also expects all of its Suppliers to adopt and enforce standards consistent with this Policy; relevant requirements may be extended to Suppliers through contractual terms and the due diligence processes described in this Policy.

2.2This Policy covers

The Policy covers:

• Checkbox’s own operations and workforce;
• Checkbox’s supply chains and its relationships with Suppliers and other business partners;
• procurement, contracting and purchasing activity, including the procurement of hardware and equipment; and
• recruitment and labour-hire arrangements engaged by or on behalf of Checkbox.

This Policy does not cover

The Policy does not separately govern general employment, work-health-and-safety or grievance matters that do not amount to Modern Slavery, which are dealt with under the relevant human resources policies.

3.Definitions

The terms not otherwise set out in the body of this Policy have the meanings given in Attachment 1 (Key terms and definitions).

4.Modern Slavery rules

4.1Zero-tolerance and prohibited conduct

Checkbox has a zero-tolerance approach to Modern Slavery. It is committed to acting ethically, transparently and with accountability in all of its business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure Modern Slavery is not taking place anywhere in its own business or in its supply chains. Checkbox, its Personnel and its Suppliers must not use or engage in any conduct consistent with the Policy Objectives (section 1.2).

4.2Identifying and assessing Modern Slavery risk

As a technology and software business, Checkbox’s risk of directly engaging in Modern Slavery is low. However, risk can still be present in its broader operations and supply chains. Checkbox focuses its attention on the following areas:

• Outsourced and offshore labour: development, support, data, moderation or business-process services delivered through third parties or in lower-cost jurisdictions, where labour-rights enforcement may vary.
• Recruitment and labour hire: use of recruitment agencies, labour-hire firms or contractors, where recruitment fees, retained documents or deceptive practices can create risk.
• Hardware and equipment procurement: purchase of IT hardware, devices, peripherals and electronics, whose upstream manufacturing supply chains are higher-risk and may engage U.S. forced-labour import laws.
• Facilities and corporate services: cleaning, security, catering, facilities management and merchandise, which can carry elevated labour-exploitation risk.
• Geographic exposure: operations, Personnel or Suppliers located in or sourcing from regions assessed as higher-risk for Modern Slavery.

4.3Due diligence, Suppliers and contracting

Checkbox takes a risk-based approach to due diligence, focusing effort where the risk of Modern Slavery is greatest. For potentially high-risk areas, our measures include:

• Supplier screening: assessing prospective and existing Suppliers for Modern Slavery risk based on sector, geography, workforce profile and the nature of goods or services.
• Supplier Code of Conduct: requiring Suppliers to commit to standards consistent with this Policy, including prohibitions on forced and Child Labour and on charging recruitment fees to workers.
• Contractual protections: where legal has assessed the risk and determined, in its sole and reasonable discretion, that a high risk exists. we include Modern Slavery warranties, audit and information rights, flow-down obligations to subcontractors, and rights to require remediation or terminate for serious breach.
• Goods and import controls: seeking assurance, for higher-risk goods such as electronics and hardware, that they are not produced with Forced or Compulsory Labour and do not originate from sources subject to import prohibitions relevant to Checkbox’s operations.
• Ongoing monitoring: re-assessing higher-risk Suppliers periodically and where circumstances change, and following up on identified concerns.

4.4Training and awareness

Checkbox provides Modern Slavery awareness training to relevant Personnel, proportionate to their role and risk exposure. Personnel in People/HR, Procurement, Finance and management, and others in higher-risk roles, receive more detailed guidance on identifying warning signs (“red flags”) and on escalation. This Policy is made available to all Personnel and is available to Suppliers.

4.5Raising concerns and grievance mechanisms

Checkbox encourages everyone to raise concerns about any issue or suspicion of Modern Slavery in any part of its business or supply chains, at the earliest possible stage. Concerns can be raised with a line manager or the Policy Owner. Reports may be made anonymously where permitted by law.

Checkbox treats reports seriously and confidentially, and will not tolerate retaliation against anyone who raises a concern in good faith or who refuses to participate in conduct that may amount to Modern Slavery.

Concerns relating to potential criminal conduct may be referred to the appropriate authorities (for example, in the Philippines, the Inter-Agency Council Against Trafficking or the IACAT 1343 Action Line; in the United States, relevant federal or state agencies; and in Australia, relevant law enforcement and the Anti-Slavery Commissioner).

4.6Remediation

If Checkbox identifies that it has caused or contributed to Modern Slavery, it will take appropriate steps to provide for or cooperate in remediation, prioritising the safety and interests of affected individuals. Where Checkbox’s operations, products or services are directly linked to Modern Slavery through a business relationship, it will use its leverage to seek to influence the responsible party to prevent or mitigate the harm, and will escalate, including by reassessing or ending the relationship, where appropriate.

If Checkbox identifies that its customers, Suppliers or partners have caused or contributed to Modern Slavery, indirectly or directly, Checkbox reserves its right to immediately terminate any contractual engagement or agreement without liability to Checkbox. Checkbox also reserves its right to notify authorities, agencies and officials required to mitigate or remediate any Modern Slavery actions or violations.

4.7Modern Slavery Statement (Australia)

If and when Checkbox becomes a reporting entity under the Modern Slavery Act 2018 (Cth) (or where it chooses to report voluntarily) it will prepare an annual Modern Slavery Statement that addresses the seven mandatory reporting criteria in section 5.1 of the Act, obtain approval from its principal governing body, and submit the statement to the Modern Slavery Statements Register within six months after the end of its financial year.

5.Prohibited Actions

This section applies to everyone who works with or for Checkbox, including its Personnel, Affiliates, and the third parties Checkbox engages or is served by, such as, Suppliers, (each a Covered Party and together Covered Parties). No Covered Party may do, permit, fund, facilitate or knowingly benefit from any of the following, at any tier of its own operations or supply chain:

• Use or benefit from Modern Slavery in any form.
• Engage in or facilitate Human Trafficking.
• Use Child Labour (including slavery and similar practices, trafficking, use in illicit activities, and hazardous work likely to harm a child's health, safety or morals) are prohibited absolutely.

• Charge Workers Recruitment Fees, deposits, bonds or collateral to get or keep work or recruitment costs are the employer's (the Employer Pays Principle).
• Take or withhold a Worker's identity, immigration or travel documents (safekeeping is allowed only with the Worker's freely given, documented consent and unrestricted access on demand).
• Create or enforce Debt Bondage.
• Withhold or delay wages, or make unlawful, coercive or disciplinary deductions.
• Recruit deceptively, including misrepresenting the job, pay, hours, location or employer, or replacing agreed terms with worse ones after a Worker commits (contract substitution), and, for cross-border hires, engage a Worker without written terms, before they start, in a language they understand.
• Restrict a Worker's freedom to move or to leave, or use threats, coercion, intimidation, harassment or abuse (including threats to family or immigration status) to compel work or silence complaints.
• Impose forced or excessive overtime, deny statutory rest, leave or days off, or penalise a Worker for resigning on reasonable notice or exercising lawful rights to organise.

• Supply goods or services produced, in whole or part, using Modern Slavery at any tier, with particular attention to IT hardware, devices and electronics.
• Supply goods subject to a forced-labour import ban or withhold release order (including under the US Tariff Act §307 / UFLPA), or from an entity or region a competent authority has linked to forced labour.

• Engage a labour broker, recruitment agent, offshore provider, employer of record or subcontractor without first conducting due diligence and flowing these same standards down to them.

• Use, configure, or resell Checkbox's websites, products or services to facilitate, conceal or enable Modern Slavery or Human Trafficking, including to advertise or arrange labour on non-compliant terms, or to process related payments.
• Disable, evade or interfere with any Checkbox screening, moderation, reporting or enforcement control relating to this Policy.

• Fail to keep accurate records of Worker age, identity, recruitment, hours and pay for at least five years, or falsify, hide or destroy them.
• Obstruct verification or coach Workers before or during an audit relating to Modern Slavery, giving false information in screening or due diligence, or otherwise frustrating checks.
• Retaliate against anyone who raises a concern in good faith, reports a violation, or cooperates with an investigation or authorities.

6.Roles and responsibilities

The following roles carry specific responsibilities under this Policy.

6.Breach and consequences

Compliance with this Policy is mandatory. Any Personnel who breach this Policy may be subject to disciplinary action, up to and including termination of employment or engagement, and potential civil or criminal liability. Suppliers who fail to meet the standards in this Policy may be required to remediate, and Checkbox may suspend or terminate the relationship for serious or unremedied breaches.

8.Review and version control

Checkbox monitors the effectiveness of the actions described in this Policy using indicators such as the proportion of higher-risk Suppliers assessed, training completion rates, and the number and outcome of concerns raised. This Policy is reviewed at least annually, and earlier if there are significant legal, organisational or supply chain changes, so that it remains current with evolving legal requirements.

Document control

Version history

Attachment 1 — Key terms and definitions

These definitions apply in addition to those terms defined in the body of the Policy:

Attachment 2 — Related documents

This Policy operates alongside the following Checkbox documents:

• Code of Conduct