Genroe (Australia) Pty Ltd
Version 1.0. Effective 20 August 2026.
1. Purpose of this policy
We will limit the risk of modern slavery practices in our business and our supply chain.
This policy sets out our commitment, what we expect of the people we work with, and how to raise a concern.
2. Scope: who this policy applies to
This policy applies to you if you are involved in our business, including if you are an employee, director, officer, labour hire staff, contractor or other representative of our business or of any business in our supply chain.
While this policy is not part of any contract you may have with us, you are expected to comply with it.
If you do not comply with this policy, we may end our business relationship with you. If you are an employee, you may be disciplined or dismissed.
3. Our reporting position
Genroe (Australia) Pty Ltd is below the AUD 100 million consolidated revenue threshold and is not a reporting entity under the Modern Slavery Act 2018 (Cth). We are not required to lodge a modern slavery statement.
We maintain this policy voluntarily because limiting modern slavery risk is the right thing to do and because our clients are entitled to know how we manage risk in our supply chain.
We are a professional services business. Our supply chain consists mainly of Australian and international software services, cloud hosting, and a small number of contractors. We regard our direct modern slavery risk as low, but not zero. The principal exposures are offshore contracted labour and the hardware and services embedded in the technology we buy.
4. What is modern slavery?
Modern slavery is depriving a person of freedom for commercial gain and in violation of fundamental human rights.
It describes situations where offenders use coercion, threats or deception to exploit victims and undermine their freedom. Modern slavery involves serious exploitation, not sub-standard working conditions or the underpayment of workers, although these may be unlawful for other reasons.
Modern slavery can take many forms, including:
- Slavery: owning a person, trading in slaves or financing slave trading (i.e. human trafficking)
- Forced labour: forcing a person to work by coercion or threats (servitude is where that person’s freedom is significantly restricted)
- Forced marriage: a marriage without free and full consent, for example due to lack of understanding, duress or coercion
- Debt bondage: a person works to pay off a large debt, for an unlimited time, or where the value of the work is not applied to the debt
- Deceptive recruiting: a recruiter charges a fee for a job offer, confiscates identity documents, or deceives a person about their personal freedom or their ability to leave the job
- Child labour: not always unlawful, but not tolerated by us where it involves exploiting children, depriving them of education, or making them work in unsafe environments
Modern slavery can be complex and multi-faceted, and can be difficult to spot.
5. Indicators of modern slavery practices
Modern slavery indicators may include where a person:
- is not in possession of their own passport, identification or travel documents;
- acts as though they are being instructed or coached by someone else, or allows others to speak for them when spoken to directly;
- is dropped off at and collected from work;
- is withdrawn, appears frightened, or has physical indicators such as injuries, or is unable to contact friends or family freely;
- has limited social interaction or contact with people outside their immediate environment, or their account of their situation contains obvious errors;
- acts with hostility, or has difficulty concentrating due to trauma, or has few possessions;
- has little or no control over their finances, has no access to a bank account, or is being significantly overcharged for accommodation; or
- is living in a very poorly maintained or overcrowded place.
These indicators are not exhaustive and do not necessarily mean there are modern slavery practices. Sometimes there are other reasons or circumstances that indicate something is not right.
6. Why we act on modern slavery risk
Limiting modern slavery practices makes good business sense. It protects the people who work for and with us, and it protects our reputation and that of our clients.
It also means we can respond credibly when clients assess modern slavery risk across their own supply chains.
7. Our responsibilities
We will endeavour to:
- address modern slavery risks in our business and supply chain; and
- take steps to raise awareness of modern slavery risks, including by maintaining and communicating this policy;
8. Your responsibilities
You must take all reasonable steps to ensure our business and supply chain is free of modern slavery practices.
However senior you are, and regardless of your business relationship with us, you must pay close attention to the higher-risk areas of our business, particularly offshore contracting, outsourcing and procurement in jurisdictions without adequate safeguards.
Specific responsibilities include:
- participating in all training, including on this policy;
- leading by example by making appropriate checks on employees, recruitment agencies and suppliers, so that we know who is working for us;
- remaining alert to the indicators of modern slavery set out above;
- using only approved contracts, which include modern slavery clauses; and
- following our instructions regarding modern slavery.
Turning a blind eye is unacceptable. If you reasonably suspect there may be modern slavery, report it under this policy.
9. How to report a concern
If you have a reasonably held suspicion of modern slavery practices, discuss your concerns with Adam Ramshaw (aramshaw@genroe.com.au), who will decide a course of action and provide further advice.
If there is immediate danger, call the police on 000. Do not tackle a situation on your own, as dangerous criminals can be behind modern slavery and human trafficking.
Not all victims want to be helped, and reporting a suspected trafficking case can put a potential victim at risk. Unless there is immediate danger, discuss your concerns with Adam Ramshaw before taking any further action.
Keep your eyes and ears open. Your awareness and actions may stop someone being exploited or abused.
10. Ownership and review
The Director of Genroe (Australia) Pty Ltd is responsible for this policy and will review any report of a material modern slavery concern.
This policy is reviewed annually. It may be amended, replaced or removed at any time. The current version is always published at www.genroe.com/static/modern-slavery-policy.