Modern Slavery Statement

HLD Group Pty Ltd (ABN 84 461 211 399) ("HLD Group", "we", "our", or "us") is an Australian cybersecurity, managed services, and technology company. We recognise that modern slavery — including forced labour, debt bondage, human trafficking, deceptive recruiting, servitude, forced marriage, and the worst forms of child labour — is a serious violation of human rights that can occur in any industry or supply chain, including our own.

We are committed to acting ethically and with integrity in all our business relationships, and to implementing and enforcing effective systems and controls to identify, assess, and mitigate the risk of modern slavery occurring in any part of our operations or supply chains. We take a zero-tolerance approach to modern slavery in any form.

This Statement describes the steps we have taken during the reporting period 1 July 2025 – 30 June 2026 to understand and address modern slavery risk, and sets out the governance, due diligence, and remediation framework we maintain on an ongoing basis.

This Statement is prepared with reference to the following frameworks, notwithstanding that mandatory reporting under the first of these does not currently apply to us:

This Statement covers HLD Group Pty Ltd and all business units, brands, and platforms we operate, including our marketing website, the Homebase security and compliance platform, and the HLD Flux content management system. It applies to our direct workforce, contractors engaged to perform work on our behalf, and our supply chains as described in Section 5.

The reporting entity for this Statement is:

HLD Group Pty Ltd is a privately held Australian proprietary company. We do not currently own or control any subsidiary entities in Australia or overseas. If our corporate structure changes — for example, through the establishment of a subsidiary, acquisition, or joint venture — this Statement will be updated to describe the structure of the consolidated group and how each entity has been consulted in the preparation of future statements (see Section 15).

Our workforce is engaged directly as employees or as individual contractors under Australian workplace law. We do not use labour hire arrangements, and we do not engage workers through recruitment agencies operating outside the standard Australian employment framework.

We design, build, and operate software and managed cybersecurity services for business customers. Our operations are knowledge-based and largely conducted by a small, directly employed and contracted professional workforce operating from Australia, supplemented by cloud infrastructure and third-party software subprocessors described in Section 5.

Our principal activities include:

• Development and operation of the Homebase security and compliance platform;
• Development and operation of the HLD Flux content management system;
• Managed cybersecurity, monitoring, and incident response services for enterprise customers;
• Professional and advisory services related to compliance, governance, and risk;
• Website and digital platform hosting and support for client organisations.

We consider our directly employed and contracted workforce to be relatively low risk for modern slavery given the professional, salaried, and skilled nature of the roles, the jurisdiction in which they are engaged, and the absence of labour hire or informal recruitment channels. Our principal exposure to modern slavery risk arises through our supply chains, described below.

Our supply chains are primarily technology-based. We maintain a register of subprocessors and suppliers, published in full at /legal/subprocessors. The principal categories of goods and services we procure are:

We do not directly manufacture goods, operate physical retail or hospitality premises, or engage in sectors that are commonly identified as high-risk for modern slavery (such as agriculture, garment manufacturing, extractives, construction, or domestic labour hire). We do, however, recognise that technology hardware supply chains — particularly at the raw materials and component manufacturing tiers, several steps removed from our direct suppliers — carry elevated modern slavery risk industry-wide, and we address this in Section 6.

We have assessed our operations and supply chains to identify areas of potential modern slavery risk, categorised by likelihood and our proximity to that risk:

We have not identified any instances of modern slavery in our operations or supply chains during the reporting period. This risk assessment will be revisited annually and whenever we materially change our supplier base, as described in Section 10.

Responsibility for modern slavery risk management is embedded in our existing governance structure rather than delegated to a standalone function, reflecting the size and risk profile of our business:

This Statement operates alongside, and is supported by, the following internal policies:

• Code of conduct — sets expectations of ethical behaviour, including respect for human rights, for all personnel.
• Vendor & third-party risk policy — governs onboarding, contractual requirements, and ongoing assessment of suppliers and subprocessors.
• Whistleblower & speak-up policy — provides a confidential channel for raising concerns, including about labour exploitation, without fear of retaliation. Available at /legal/whistleblower.
• Anti-bribery & corruption policy — prohibits improper payments that can mask or enable exploitative labour practices in supply chains.
• Personnel security policy — governs fair, lawful, and consensual engagement of our own workforce.
• Complaints handling policy — provides a general mechanism for any person to raise a concern about our conduct. Available at /legal/complaints.

Standard supplier contract terms require compliance with applicable labour, employment, and human rights laws in the supplier’s jurisdiction of operation, and prohibit the use of forced, bonded, or child labour by the supplier or its own subcontractors.

We apply the following due diligence steps, scaled to the risk level identified in Section 6:

We assess modern slavery risk across our supplier base using three factors:

Suppliers assessed as higher risk against these factors receive the enhanced due diligence described in Section 9. This methodology is reviewed annually and updated to reflect changes in our supplier base or in publicly available risk data.

During the reporting period 1 July 2025 – 30 June 2026, we:

• Published and maintained a full subprocessor and supplier register at /legal/subprocessors, updated as vendors change;
• Reviewed our standard supplier contract terms to confirm inclusion of lawful labour practice warranties and cooperation obligations;
• Maintained our whistleblower and complaints channels, described in Section 12, as an accessible route for any person to raise a concern;
• Assessed our supplier base against the risk categories in Section 6 and confirmed no substantiated modern slavery concerns were identified or reported;
• Reviewed this Statement and the policies referenced in Section 8 for continued accuracy and alignment with the criteria in Section 2.

As our operations, headcount, and supplier base grow, we intend to expand these actions to include formal supplier self-assessment questionnaires and periodic refresher training for procurement and people-management personnel.

Consistent with the UN Guiding Principles on Business and Human Rights, we are committed to providing or cooperating in legitimate remediation where we identify that we have caused or contributed to a modern slavery harm, and to using our leverage to encourage remediation where a harm is directly linked to our operations, products, or services through a business relationship even if we did not contribute to it.

Where a credible concern is raised, we will:

1. Assess the concern promptly and, where necessary, engage the relevant supplier for information;
2. Prioritise the safety and wellbeing of any person who may be at risk, including preserving confidentiality and protecting against retaliation;
3. Where a concern is substantiated, require the supplier to implement a remediation plan, which may include back-payment of wages, return of recruitment fees, or other corrective action for affected workers;
4. Suspend or terminate the supplier relationship where remediation is not undertaken in good faith or the risk cannot be adequately addressed;
5. Report on outcomes to our principal governing body.

We have not identified or received any reports of modern slavery requiring remediation during the reporting period.

Personnel involved in procurement, vendor management, and people functions are made aware of the indicators of modern slavery, our escalation process, and the whistleblower channel described in Section 16 as part of our security and awareness training programme. Awareness content is reviewed alongside this Statement on an annual basis and updated to reflect emerging risk areas identified in our sector.

We assess the effectiveness of our actions using the following measures:

• The proportion of suppliers above our materiality threshold that have completed onboarding due diligence under Section 9;
• Whether any concerns raised through the channels in Section 16 relate to labour practices, and how they were resolved;
• Whether standard supplier contract terms continue to include the protections described in Section 9.2;
• Annual review of this Statement and its underlying risk assessment by our principal governing body.

We recognise that as a small organisation without direct operations in high-risk sectors, our current effectiveness measures are necessarily proportionate to our size and risk profile. We intend to develop more granular key performance indicators, including supplier self-assessment completion rates, as our supplier base grows.

As described in Section 3, HLD Group Pty Ltd does not currently own or control any subsidiary entities. This Statement has therefore been prepared solely with respect to HLD Group Pty Ltd. If we come to own or control other entities, this Statement will describe the process by which each entity was consulted in its preparation, consistent with the consultation requirement under section 16(1)(f) of the Modern Slavery Act 2018 (Cth).

Anyone — including our personnel, contractors, suppliers, customers, or members of the public — who has a genuine concern that modern slavery may be occurring in our operations or supply chains can report it through any of the following channels:

All reports are assessed under the process described in Section 12. If you believe someone is in immediate danger, please contact local emergency services or, in Australia, the Australian Federal Police Human Trafficking hotline in addition to notifying us.

This Statement was approved by the principal governing body of HLD Group Pty Ltd and is signed by a responsible member of the organisation, consistent with the approval and signature requirements of section 14 of the Modern Slavery Act 2018 (Cth).

We review and, where necessary, update this Statement at least annually, and whenever we make a material change to our structure, operations, or supply chains that could affect our modern slavery risk profile. We will indicate the date of the most recent update at the top of this page. Older versions of this Statement are available on request.

For questions about this Statement or our approach to modern slavery risk, please contact:

To raise a concern about suspected modern slavery, see the channels described in Section 16.