Anti-Slavery Policy

Purpose

This policy outlines Vaxa’s commitment to ensuring, to the best of our ability, that there is no modern slavery in any part of our business operations or supply chain. We are dedicated to acting ethically and with integrity in all business dealings and relationships, in compliance with the Modern Slavery Act 2018 (Cth).

Scope

This policy applies to all employees, contractors, suppliers, service providers, and any other parties working on behalf of Vaxa.

Roles & Responsibilities

Policy Statement

We are committed to:

• Prohibiting Modern Slavery: Including specific prohibitions against the use of forced, compulsory, or trafficked labour, or anyone held in slavery or servitude, in all our contracts.
• Ethical Expectations: Expecting our service providers, suppliers, and contractors to share our commitment to act lawfully and ethically, ensuring modern slavery does not occur within their organisations or supply chains.
• Due Diligence: Conducting due diligence on suppliers to assess their compliance with anti-slavery measures.
• Training: Providing training to employees on modern slavery risks and indicators.
• Reporting Mechanisms: Encouraging the reporting of any concerns related to modern slavery.

Under the Modern Slavery Act 2018 (Cth) ‘Act’, we are not required to publish a Modern Slavery Statement as we have an annual consolidated revenue of less than $100 million. However, we are committed to ensuring that modern slavery does not occur within our operations or supply chain.

Prohibited Practices

Vaxa explicitly prohibits all employees, workers, contractors, agents, suppliers, and any other parties acting on our behalf from engaging in any of the following practices, in any part of our operations or supply chain:

• Forced labour, child labour and human trafficking: Any form of forced or compulsory labour, child labour, or human trafficking.
• Worst forms of child labour: Hazardous child labour, being work performed by a person under the age of 18 that jeopardises their physical, mental, or moral well-being, including work performed for long hours, during the night, or under other particularly difficult or dangerous conditions.
• Child labour: The employment or engagement of any person below the applicable minimum age for completing compulsory schooling, and in any case not less than 15 years of age (or the applicable local legal minimum age where higher).
• Withholding of identity or immigration documents: Confiscating, destroying, concealing, or otherwise denying workers access to their identity documents, immigration documents, work permits, or other personal documents.
• Discrimination: Discrimination before hiring, on the job, or upon leaving employment on the basis of race and/or colour, sex, religion, political opinion, national extraction, age, HIV/AIDS status, disability, nationality, sexual orientation, family responsibilities, or trade union membership or activities.
• Recruitment fees: Charging workers or potential workers, directly or indirectly, any fees or costs associated with their recruitment or employment.
• Commercial sexual exploitation: Procuring or facilitating commercial sex acts at any time during the length of a work contract.

Worker Protections

Vaxa is further committed to ensuring that:

• Freedom to leave employment: Workers, including migrant workers, may cancel their work contract at any time without financial penalty, subject to giving reasonable notice in accordance with local law or an applicable collective agreement.
• Fair wages: Wages meet applicable host country legal minimum wage requirements or, where no legal minimum wage applies, are aligned with the prevailing wage for the relevant sector.
• Freedom of association: Workers have the right to form and join trade unions of their own choosing, to bargain collectively, and to engage in peaceful assembly, in conformance with local law.
• Transparent work agreements: Workers, including those engaged through recruiters, are provided with detailed and accurate work agreements or equivalent work papers, in a language they understand, prior to commencing work (and prior to relocation, where relocation is required).
• Document and age verification: All workers undergo document checks, including verification of proof-of-age documents, before commencing work, to confirm they are legally permitted to work in accordance with applicable law and Vaxa policy.

Definitions

The term ‘modern slavery’ describes situations where coercion, threats or deception are used to exploit victims and undermine their freedom. Coercion, threats and deception can be explicit or implicit.

The Act defines modern slavery as including eight types of serious exploitation; trafficking in persons, slavery, servitude, forced labour, forced marriage, debt bondage, the worst forms of child labour and deceptive recruiting for labour or services.

The worst forms of child labour means extreme forms of child labour that involve the serious exploitation of children, including through enslavement or exposure to dangerous or hazardous work — that is, work performed by a person under the age of 18 that jeopardises their physical, mental or moral well-being, including work performed for long hours or during the night. The worst forms of child labour does not mean all child work.

Child labour means work performed by a person below the age for completing compulsory schooling, and in general not less than 15 years of age.

Under Australian law, modern slavery is defined in the Act. In the event of any inconsistency between this policy and the Act, the Act will prevail.

Exceptions

No exceptions to this policy are permitted.

Compliance & Monitoring

We will ensure compliance by:

• Regular Audits: Conducting regular audits of our operations and supply chain.
• Supplier Risk Assessments: Requiring suppliers to complete a modern slavery risk assessment prior to onboarding, and at least annually thereafter as part of ongoing supplier engagement.
• Policy Review: Reviewing and updating the policy annually.
• Reporting: Monitoring reports of any concerns related to modern slavery.

References

• Modern Slavery Act 2018 (Cth)
• Vaxa’s Code of Conduct