Modern Slavery and Ethical Supply Chain Policy

Last updated: 23 July 2026

1. Purpose

flowprofiler® Pty Ltd is committed to conducting business ethically and respecting the dignity, freedom and human rights of the people who contribute to our operations and supply chains.

We do not tolerate modern slavery, human trafficking, forced labour, servitude, debt bondage, forced marriage, deceptive recruitment, the worst forms of child labour or other serious forms of labour exploitation.

This policy explains how we seek to identify, prevent, mitigate and respond to modern slavery risks in our operations and supply relationships.

2. Status of this policy

This is a voluntary organisational policy.

It is not intended to represent that flowprofiler® Pty Ltd is currently required to publish an annual statutory modern slavery statement.

We will review our reporting status periodically. If flowprofiler® Pty Ltd becomes subject to a mandatory reporting requirement, we will prepare, approve and publish the required annual statement in accordance with the applicable law.

3. Who we are

flowprofiler® Pty Ltd is an Australian company that publishes and provides:

  • workplace psychometric assessments;
  • behavioural intelligence products;
  • assessment and reporting technology;
  • leadership and organisational development;
  • training and professional development;
  • coaching and facilitated services; and
  • related intellectual property and digital resources.

Our services are provided primarily through digital platforms, professional services, authorised practitioners, trainers, contractors and business suppliers.

4. Scope

This policy applies to:

  • directors;
  • employees;
  • contractors;
  • consultants;
  • trainers and facilitators;
  • authorised delivery partners;
  • suppliers and service providers;
  • developers and technology providers;
  • recruitment and labour providers; and
  • other parties acting for or on behalf of flowprofiler® Pty Ltd.

It applies to our own operations and to procurement and supply relationships over which we have influence or control.

5. What we mean by modern slavery

Modern slavery describes serious exploitation in which a person cannot freely refuse or leave a situation because of threats, violence, coercion, deception, abuse of power or another form of control.

It may include:

  • slavery and slavery-like practices;
  • human trafficking;
  • servitude;
  • forced or compulsory labour;
  • debt bondage;
  • deceptive recruitment;
  • forced marriage;
  • forced sexual exploitation;
  • the worst forms of child labour; and
  • other conduct treated as modern slavery under applicable law.

Modern slavery can occur in any country and in both goods and service supply chains.

6. Our commitment

flowprofiler® Pty Ltd is committed to:

  • complying with applicable employment, workplace and modern slavery laws;
  • treating workers, contractors and suppliers with dignity and respect;
  • avoiding business practices that knowingly contribute to labour exploitation;
  • applying due diligence proportionate to the nature and risk of a supplier relationship;
  • encouraging concerns to be raised without fear of retaliation;
  • responding appropriately to credible concerns;
  • considering the safety and interests of affected people when deciding how to respond;
  • working with suppliers to improve practices where remediation is possible and appropriate; and
  • reviewing our approach as our business, products and supply chains develop.

We recognise that no organisation can guarantee that modern slavery will never occur within every part of its extended supply chain.

Our responsibility is to take reasonable and proportionate steps to understand relevant risks, avoid causing or contributing to harm, and respond appropriately when concerns arise.

7. Our operations and supply relationships

As a workplace assessment, professional services and technology business, our direct operations are primarily knowledge based.

Our supply relationships may include:

  • cloud hosting and data infrastructure;
  • software and technology providers;
  • website and platform development;
  • cybersecurity and technical support;
  • computer equipment and electronic devices;
  • professional consultants and contractors;
  • authorised trainers, coaches and facilitators;
  • recruitment and labour services;
  • printing, publishing and promotional materials;
  • marketing and communications services;
  • payment, accounting and financial services;
  • office, cleaning and facilities services;
  • venues, accommodation and event services;
  • learning and content providers; and
  • other professional and operational suppliers.

Modern slavery risk may exist beyond a direct supplier, including within subcontracting arrangements, labour providers, manufacturing, raw materials, logistics and overseas service delivery.

8. Risk based approach

We apply a proportionate and risk based approach rather than treating every supplier as presenting the same level of risk.

Factors that may indicate increased risk include:

  • operations or sourcing in locations with weak labour protections or enforcement;
  • industries that rely heavily on temporary, migrant, low paid or vulnerable workers;
  • complex or opaque subcontracting arrangements;
  • recruitment agents or labour intermediaries;
  • unusually low pricing or unrealistic delivery expectations;
  • extensive use of outsourced or offshore labour;
  • the manufacture of electronics, promotional products, clothing or printed goods;
  • cleaning, hospitality, construction, agriculture, transport or logistics services;
  • workers being charged recruitment or placement fees;
  • restrictions on workers’ movement;
  • retention of passports or identity documents;
  • unexplained wage deductions;
  • excessive working hours;
  • threats, intimidation or coercion;
  • credible adverse media, regulatory action or worker allegations; and
  • a supplier’s unwillingness to explain its labour practices or supply chain.

The presence of a risk factor does not automatically establish that modern slavery is occurring. It indicates that further enquiry may be appropriate.

9. Supplier selection and due diligence

Due diligence will be proportionate to the value, nature, location and risk of the relationship.

Depending on the circumstances, we may:

  • confirm the supplier’s legal identity and ownership;
  • review where and how services or products are delivered;
  • consider country, sector and labour risks;
  • review the supplier’s modern slavery statement or relevant policies;
  • ask questions about employment, recruitment and subcontracting practices;
  • assess the supplier’s use of overseas workers or supply chains;
  • seek confirmation that workers are free to leave employment;
  • ask whether recruitment fees are charged to workers;
  • review credible public information and regulatory findings;
  • require appropriate contractual commitments;

request supporting evidence or corrective action;

  • conduct additional enquiries for higher risk relationships; and
  • decline, suspend or end a relationship where risks cannot be appropriately addressed.

We will not make unnecessary or disproportionate demands of small suppliers where the nature of the relationship presents a low risk.

10. Supplier expectations

We expect suppliers and business partners to:

  • comply with applicable employment, workplace and human rights laws;
  • prohibit forced, trafficked, bonded and involuntary labour;
  • prohibit unlawful child labour;
  • ensure workers are free to leave employment in accordance with applicable law;
  • not retain passports or identity documents as a means of control;
  • not require workers to pay improper recruitment fees;
  • provide clear and accurate employment terms;
  • pay lawful wages and entitlements;
  • provide safe and respectful working conditions;
  • avoid threats, violence, intimidation and degrading treatment;
  • provide reasonable methods for workers to raise concerns;
  • avoid retaliation against people who raise concerns;
  • conduct proportionate due diligence on relevant subcontractors;
  • notify us of credible modern slavery concerns connected with services supplied to flowprofiler®; and
  • cooperate reasonably with enquiries and remediation.

These expectations may be included in supplier agreements, purchase terms, questionnaires or other procurement documents where appropriate.

11. Employment and recruitment practices

flowprofiler® Pty Ltd seeks to ensure that people working directly for us:

  • enter work voluntarily;
  • receive clear information about the nature and terms of their engagement;
  • are paid in accordance with applicable law and agreement;
  • are not required to surrender passports or identity documents;
  • are not charged improper recruitment fees;
  • may end their employment or engagement in accordance with applicable terms and law;
  • have access to a means of raising concerns; and
  • are not subjected to threats, coercion or retaliation.

Where recruitment agencies or labour providers are used, we may undertake additional checks proportionate to the nature and risk of the arrangement.

12. Purchasing practices

We recognise that purchasing decisions can contribute to poor labour practices where suppliers are expected to deliver services or products:

  • at unrealistic prices;
  • within unreasonable timeframes;
  • through frequent or unexplained changes;
  • without adequate resources; or
  • under terms that transfer excessive risk to vulnerable workers.

We will seek to avoid procurement practices that knowingly encourage unlawful wages, excessive hours, coercive labour or unsafe working conditions.

13. Raising a concern

Anyone may raise a concern about suspected modern slavery or serious labour exploitation connected with flowprofiler® Pty Ltd, its contractors or its suppliers.

Concerns may be sent to:
Managing Director
flowprofiler® Pty Ltd

Email: hello@flowprofiler.com

Please use the subject line:
Confidential: Modern Slavery Concern

A concern may be raised by an employee, contractor, participant, client, supplier, worker or member of the public.

Where possible, the report should include:

  • what happened or is suspected;
  • who may be affected;
  • the supplier, organisation or location involved;
  • when the concern arose;
  • any immediate safety risk; and
  • any information or evidence that may assist.

A person should not place themselves or another person at risk, confront a suspected exploiter or attempt to conduct their own investigation.

Where there is an immediate threat to life or safety, emergency services should be contacted.

14. Confidentiality and protection from retaliation

Concerns will be handled sensitively and shared only with people who reasonably need the information to assess or respond.

flowprofiler® Pty Ltd will not tolerate retaliation against a person who raises a genuine concern in good faith or participates in an enquiry.

Deliberately false or malicious allegations are not protected. A concern will not be considered malicious merely because it is not ultimately substantiated.

Anonymous reports may be considered, although anonymity may limit our ability to investigate or communicate an outcome.

15. Responding to concerns

Where a credible concern is raised, flowprofiler® Pty Ltd will determine an appropriate response based on the circumstances.

This may include:

  • considering immediate safety and welfare;
  • preserving confidentiality and relevant information;
  • obtaining specialist advice;
  • contacting an appropriate authority or support service;
  • asking the supplier for information;
  • investigating contractual and supply chain links;
  • requiring corrective action;
  • increasing monitoring;
  • suspending new work or payments where lawful and appropriate;
  • supporting access to remedy;
  • notifying an affected client;
  • reporting the matter where required or appropriate; and
  • suspending or terminating a supplier relationship.

We will avoid taking action that is likely to increase harm to an affected person.

Immediate termination will not automatically be the preferred response. Where safe and appropriate, engagement and remediation may produce a better outcome for affected workers.

Termination may be appropriate where:

  • serious harm is continuing;
  • the supplier refuses to cooperate;
  • the supplier conceals relevant information;
  • meaningful remediation is not possible;
  • corrective action is not implemented; or
  • continued engagement would create unacceptable legal, ethical or safety risk.

16. Remedy

Where flowprofiler® Pty Ltd identifies that it has caused or contributed to harm, we will seek to participate in appropriate remediation.

Depending on the circumstances, remediation may involve:

  • addressing an immediate safety need;
  • correcting a purchasing or contracting practice;
  • supporting repayment of improper fees or withheld entitlements;
  • requiring a supplier corrective action plan;
  • supporting access to specialist services;
  • cooperating with authorities;
  • strengthening contractual or due diligence controls; or
  • another response designed around the needs and interests of affected people.

Remediation must not prevent a person from contacting authorities or exercising a legal right.

17. Training and awareness

Information and training will be provided in a manner proportionate to each person’s responsibilities.

People involved in procurement, contracting, recruitment, supplier management or responding to concerns may receive guidance concerning:

common forms of modern slavery;

  • relevant risk indicators;
  • higher risk products and services;
  • responsible purchasing;
  • supplier due diligence;
  • how to respond to a concern;
  • confidentiality and non-retaliation; and
  • escalation and record keeping.

18. Responsibilities

Managing Director

The Managing Director is the owner of this policy and is responsible for:

  • approving the policy;
  • overseeing material modern slavery concerns;
  • approving significant supplier responses;
  • ensuring appropriate governance and resources; and
  • determining whether statutory reporting obligations apply.

Contract and supplier owners

People who select or manage suppliers are responsible for:

  • considering modern slavery risk where relevant;
  • completing proportionate checks;
  • maintaining appropriate supplier records;
  • applying approved contractual requirements;
  • reporting warning signs; and
  • monitoring agreed corrective actions.

Employees, contractors and representatives

Everyone acting for flowprofiler® Pty Ltd must:

  • comply with this policy;
  • avoid knowingly participating in exploitative practices;
  • report credible concerns promptly;
  • cooperate with enquiries; and
  • preserve confidentiality.

No individual is expected to investigate suspected criminal conduct personally.

19. Monitoring effectiveness

We will progressively monitor the effectiveness of our approach through measures proportionate to our size, operations and risk.

These may include:

  • the number or proportion of material suppliers risk screened;
  • higher risk suppliers subject to additional due diligence;
  • relevant supplier contracts containing modern slavery provisions;
  • training or guidance completed by relevant personnel;
  • concerns raised and assessed;
  • corrective actions implemented;
  • unresolved supplier risks;
  • identified improvements to procurement practices; and
  • completion of annual policy and reporting reviews.

Measures will be interpreted carefully. A low number of reported concerns does not necessarily demonstrate that no risk exists.

20. Records and privacy

Modern slavery enquiries, due diligence and reports may involve sensitive personal or commercial information.

Information will be:

  • collected only where reasonably necessary;
  • handled confidentially;
  • shared on a need to know basis;
  • stored securely;
  • retained according to the Data Retention and Destruction Schedule; and
  • disclosed where required or appropriately authorised.

Personal information will be handled in accordance with the flowprofiler® Privacy Policy and Data Protection Policy.

21. Breaches of this policy

A breach of this policy may result in:

  • additional training;
  • corrective action;
  • suspension of access or authority;
  • disciplinary action;
  • termination of employment or contract;
  • supplier remediation;
  • suspension or termination of a supplier relationship;
  • notification to a client or authority; or
  • legal action,
  • depending on the circumstances and applicable law.

22. Review and statutory reporting

This policy will be reviewed

  • at least annually;
  • when flowprofiler® enters a materially different market;
    when a higher risk supplier or product category is introduced;
    following a material concern or incident;
    when applicable law changes; or
    when the size or structure of the business changes materially.

As part of the review, flowprofiler® Pty Ltd will assess whether it has become subject to a mandatory modern slavery reporting requirement in Australia, the United Kingdom or another jurisdiction.

Where mandatory reporting applies, the statutory statement will be separately:

  • prepared for the applicable reporting period;
  • based on steps actually taken;
  • approved by the appropriate governing body;
  • signed by an authorised responsible person;
  • published in the required location; and
  • Submitted to a government register where required.

23. Related documents

This policy should be read with:

  • Code of Conduct;
  • Whistleblowing or Speak Up Policy;
  • Procurement and Supplier Due Diligence Procedure;
  • Supplier Code of Conduct;

Privacy Policy;

  • Data Protection Policy;
  • Data Retention and Destruction Policy;
  • Data Breach Response Plan;

Contractor and Practitioner Agreements; and applicable supplier and service agreements.

Where one of these documents has not yet been formally adopted, the relevant requirement in this policy continues to apply.

24. Contact

Questions or concerns about this policy may be directed to:

Managing Director
flowprofiler® Pty Ltd

Email: hello@flowprofiler.com