Modern Slavery Policy

1. Purpose

Round ABT Pty Ltd is committed to ensuring that our business operations and supply chains are free from any form of modern slavery. We recognize that modern slavery is a serious violation of human rights and includes crimes such as forced labor, debt bondage, human trafficking, and child labor. We are committed to acting ethically and with integrity in all our business dealings.

2. Scope

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, and external consultants.

3. Our Operations and Supply Chain

We acknowledge that modern slavery can occur in any industry and at any level of a supply chain. Our business operations primarily involve procurement, travel, consulting and digital services. We source goods and services from various suppliers, and we expect these partners to uphold the same high standards of ethical conduct.

4. Our Commitment

We are committed to:

• Compliance: Adhering to the Modern Slavery Act 2018 (Cth) and all other relevant Australian labor laws.

• Zero Tolerance: Maintaining a zero-tolerance approach to modern slavery in our business and supply chains.

• Due Diligence: Assessing and managing risks by reviewing our suppliers and their practices where possible.

• Transparency: Encouraging openness and supporting anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

5. Supplier Expectations

We expect our suppliers to:

• Comply with all applicable local and international labor laws.

• Prohibit the use of forced, bonded, or involuntary labor.

• Ensure that workers are of legal age and are not exploited.

• Provide safe and healthy working conditions for their employees.

• Pay at least the minimum legal wage and provide all statutory benefits.

6. Responsibility for the Policy

The Board has overall responsibility for ensuring this policy complies with our legal and ethical obligations. Management at all levels is responsible for ensuring those reporting to them understand and comply with this policy.

7. Training and Awareness

We will provide training on this policy as part of the induction process for all new employees. Our zero-tolerance approach to modern slavery will be communicated to all suppliers, contractors, and business partners at the outset of our business relationship.

8. Reporting Concerns

If you suspect or become aware of any instance of modern slavery within our operations or supply chain, you are encouraged to report it immediately to the board. If you are in Australia and suspect an immediate crime, you should contact the Australian Federal Police.

9. Breach of Policy

Any employee who breaches this policy may face disciplinary action, which could result in dismissal for misconduct. We may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy.