Modern Slavery Policy

1. Introduction

WorkingHomes has zero tolerance for modern slavery and human trafficking. We are committed to acting ethically and with integrity in all our business relationships, and to respecting the human rights of everyone our work touches — including the workers we house.

The Modern Slavery Act 2018 (Cth) requires larger entities (annual consolidated revenue of A$100 million or more) to publish modern slavery statements. We publish this policy voluntarily because we believe businesses of every size have a part to play.

2. Scope

This policy applies to our employees and contractors, and we expect the accommodation providers, suppliers and business partners we work with to share its standards.

3. What modern slavery means

Modern slavery describes serious exploitation, including forced labour, debt bondage, servitude, deceptive recruitment, human trafficking and the worst forms of child labour. It is a crime and a serious violation of human rights.

4. Our commitments

1. Compliance — we comply with all applicable laws, including the Modern Slavery Act and the Criminal Code Act 1995 (Cth).
2. Due diligence — we assess the risk of modern slavery in our operations and supply chain, and act on what we find.
3. Supplier standards — we expect accommodation providers and suppliers to treat their workers fairly and lawfully.
4. Awareness — our team knows how to recognise the signs of exploitation and what to do about them.
5. Speaking up — anyone can raise a concern with us confidentially and without fear of reprisal.

5. Where the risks are

Our direct operations are small and low-risk. The higher-risk areas are in our wider supply chain — cleaning and laundry services, property maintenance, and the furniture and linen supply chains behind the homes we use. Because we house workers, we may also see signs of exploitation first-hand, such as overcrowding or people who do not appear to control their own documents, pay or movements. We take any such signs seriously.

6. Actions we take

• checking new accommodation providers and suppliers before we work with them;
• including clear standards on fair and lawful treatment of workers in our agreements;
• honouring agreed occupancy limits and reporting suspected overcrowding;
• paying our suppliers fairly and on time; and
• keeping this policy up to date as laws and good practice change.

7. Reporting concerns

If you have a concern about modern slavery connected to our business, please contact us at [email protected]. Every report is treated confidentially, investigated promptly and handled appropriately, and no one will be disadvantaged for raising a genuine concern.

If someone is in immediate danger, call 000. To report suspected human trafficking or slavery, contact the Australian Federal Police on 131 AFP (131 237).

8. Monitoring and review

Our directors are responsible for this policy and its implementation. We review it every year and update it as needed to keep it effective.

Approved by

Pierce Duffy

Position

Director, WorkingHomes Pty Ltd

Date

22 October 2026