Modern Slavery Policy

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Introduction

Real World Technology Solutions (RWTS) is committed to conducting business in a manner that respects the human rights and dignity of all people. This Modern Slavery Policy and our forthcoming Impact Statement establishes our commitment to preventing modern slavery and human trafficking in our operations and supply chains, in line with our core values of integrity, ethics, and a human-centric focus.

 

As a locally and family-owned Australian business providing technology and telecommunications solutions, we recognize our responsibility to identify, prevent, and address modern slavery risks. While we are not a mandatory reporting entity under the Modern Slavery Act 2018 (Cth), we voluntarily choose to document our approach to managing modern slavery risks as part of our broader commitment to ethical business practices.

Purpose and Scope

This policy serves to:

  1. Outline our commitment to combating modern slavery and human trafficking
  2. Establish a framework for identifying and addressing modern slavery risks
  3. Define responsibilities for the implementation of this policy
  4. Guide our approach to due diligence, risk assessment, and remediation
  5. Complement our existing Human Rights Policy and Supplier Code of Conduct

This policy applies to all operations of Real World Technology Solutions, including our interactions with suppliers, contractors, business partners, and clients.

What is Modern Slavery?

Modern slavery describes situations where coercion, threats, or deception are used to exploit individuals and undermine or deprive them of their freedom. Modern slavery encompasses:

  • Human trafficking
  • Slavery
  • Servitude
  • Forced labor
  • Debt bondage
  • Deceptive recruiting for labor or services
  • Forced marriage
  • Child labor and the worst forms of child labor

 

These practices are serious crimes and violations of fundamental human rights.

Our Commitment

Real World Technology Solutions is committed to:

  1. Operating ethically: Conducting all business activities in an ethical and transparent manner, respecting human rights and taking action to prevent modern slavery.
  2. Risk assessment: Regularly assessing the risk of modern slavery in our operations and supply chains, with particular focus on high-risk sectors, products, and geographies.
  3. Due diligence: Implementing due diligence processes for our suppliers, business partners, and within our own operations to identify, prevent, and mitigate modern slavery risks.
  4. Supplier engagement: Working with our suppliers to ensure they understand and comply with our expectations regarding modern slavery and human rights.
  5. Training and awareness: Providing appropriate training to our staff on modern slavery risks and our policies and procedures.
  6. Grievance mechanisms: Maintaining effective and accessible channels for reporting concerns about modern slavery risks or incidents.
  7. Remediation: Taking appropriate action to address any identified instances of modern slavery, including providing for or cooperating in remediation where appropriate.
  8. Continuous improvement: Regularly reviewing and improving our approach to addressing modern slavery risks.

Risk Assessment and Due Diligence

Real World Technology Solutions will undertake risk assessments to identify potential modern slavery risks in our operations and supply chains. Our approach includes:

  1. Mapping our supply chains to identify high-risk categories, sectors, and geographies
  2. Engaging with suppliers to understand their approach to modern slavery risks
  3. Conducting due diligence on new and existing suppliers, with enhanced due diligence for those in high-risk categories
  4. Monitoring compliance with our Supplier Code of Conduct and contractual requirements

 

In line with our Human Rights Policy and Supplier Code of Conduct, we expect our suppliers to:

  • Prohibit forced labor, child labor, and human trafficking
  • Ensure fair and legal employment terms and working conditions
  • Respect freedom of association and collective bargaining rights
  • Provide fair wages and benefits
  • Ensure reasonable working hours
  • Prevent harassment and abuse
  • Provide safe and healthy working conditions

Implementation and Governance

The responsibility for implementing this policy lies with:

  1. The Executive Team: Overall accountability for the implementation of this policy and ensuring sufficient resources are allocated.
  2. Procurement Team: Responsibility for supplier engagement, due diligence, and monitoring compliance.
  3. Human Resources: Responsibility for internal training, awareness, and ensuring our recruitment and employment practices are free from modern slavery risks.
  4. All Employees: Responsibility for being aware of modern slavery risks and reporting any concerns.

Reporting Concerns

We encourage anyone with concerns about potential violations of this policy to report them. Reports can be made to:

All reports will be treated confidentially to the extent possible, and no retaliation will be tolerated against anyone who, in good faith, raises a concern or reports a violation.

Training and Communication

Real World Technology Solutions will provide appropriate training to staff on modern slavery risks and our approach to addressing these risks. This includes:

  1. General awareness training for all staff
  2. Specialized training for staff in roles with higher exposure to modern slavery risks, such as procurement and human resources
  3. Regular updates on modern slavery risks and our policies through internal communications
  4. Engagement with suppliers to communicate our expectations and support their capacity to address modern slavery risks

Monitoring and Reporting

We will monitor the effectiveness of our approach to addressing modern slavery risks through:

  1. Key performance indicators relating to supplier due diligence, risk assessment, and training
  2. Regular reviews of our policies and procedures
  3. Annual internal reporting on our progress in addressing modern slavery risks
  4. A voluntary Modern Slavery Impact Statement, which will be reviewed and updated annually

Impact Statement

As a non-mandatory reporting entity, Real World Technology Solutions will voluntarily provide an impact statement to demonstrate our commitment to transparency and accountability in addressing modern slavery risks.

Our Structure, Operations, and Supply Chains

Real World Technology Solutions is a locally and family-owned Australian business providing technology and telecommunications solutions. Our operations include:

  • Provision of internet and VOIP telecommunication services and technologies
  • Telecommunications network provision (as a licensed carrier)
  • Managed IT services
  • IT consulting and security services
  • Venue installation services
  • Electrical services
  • Commissioning services
  • Audio visual services
  • Network infrastructure design and implementation

Our primary supply chains include:

  • Technology hardware suppliers
  • Software providers
  • Telecommunications service providers
  • Professional services providers
  • Office supplies and equipment

Risks of Modern Slavery in Our Operations and Supply Chains

Based on our risk assessment, we have identified the following potential modern slavery risks in our operations and supply chains:

  1. Technology hardware: Some components may be manufactured in countries with higher risks of labor exploitation
  2. Telecommunications and electrical equipment: Components used in network infrastructure, electrical installations, and audio-visual systems may come from supply chains with elevated modern slavery risks
  3. Installation and commissioning services: Use of subcontractors for venue installations, electrical work, and on-site services may involve vulnerable worker populations
  4. Contracted services: Services such as cleaning, maintenance, or labor hire may involve vulnerable worker populations
  5. Supply chain visibility: Limited visibility into multiple tiers of suppliers, particularly for complex electronic components and equipment
  6. Office supplies: Certain products may involve raw materials from regions with higher modern slavery risks

Actions Taken to Address Modern Slavery Risks

In the past year, Real World Technology Solutions has taken the following actions to assess and address modern slavery risks:

  1. Developed this Modern Slavery Policy
  2. Reviewed and updated our Human Rights Policy and Supplier Code of Conduct
  3. Conducted an initial risk assessment of our key suppliers and subcontractors
  4. Included modern slavery considerations in our procurement processes
  5. Implemented subcontractor management protocols for installation and electrical services
  6. Enhanced due diligence for telecommunications and audio-visual equipment suppliers
  7. Raised awareness among our staff about modern slavery risks
  8. Incorporated modern slavery clauses in subcontractor agreements

Assessing Effectiveness

We assess the effectiveness of our actions through:

  1. Supplier engagement and feedback
  2. Staff awareness and reporting mechanisms
  3. Regular review of our policies and procedures
  4. Tracking key performance indicators related to supplier due diligence

Consultation Process

In developing this policy and our impact statement, we consulted with key stakeholders across our business, including the executive team, procurement, human resources, and legal advisors.

Future Commitments

Over the next year, Real World Technology Solutions commits to:

  1. Deepen our understanding of modern slavery risks in our operations and supply chains
  2. Enhance our due diligence processes for high-risk suppliers
  3. Develop more comprehensive training for staff in key roles
  4. Strengthen our approach to supplier engagement on modern slavery issues
  5. Review and improve our grievance mechanisms

Approval

This Modern Slavery Policy was approved by the executive leadership team of Real World Technology Solutions on 1st April 2025.

This policy will be reviewed annually to ensure it remains relevant and effective.

For further information or questions regarding this policy, please contact Andrew Yager on 1300 798 718.