Anti-modern slavery statement

 This Anti-Modern Slavery Statement (AMS Statement) is made in accordance with the Modern Slavery Act 2018 (Cth) for the year ending on 31 March 2025 (‘RYE 2025) by Datacom Australia Holdings Pty Limited (ABN 45 094 235 373) and its ‘Reporting Entities’ (jointly ‘Datacom’).

This is now our sixth AMS Statement.

For the previous reporting year (RYE 2024), we updated our AMS Statement to include some of the recommendations from the Report of the Statutory Review of the Modern Slavery Act 2018 (Report) released by the Federal Attorney General in Australia in May 2023, to help the reader better assess our response to modern slavery issues.  We note that the Australian Government’s response to the Report released on 2 December 2024 agreeing in full or in principle to 25 of the 30 recommendations from the Report.  We expect further developments in anti-modern slavery legislative framework in Australia. 

Datacom continues to take the issue of modern slavery seriously. We have voluntarily extended our reporting to include all the companies owned and controlled by Datacom Group Limited (our parent company in New Zealand). This also includes our companies that we own in Asia (Malaysia, the Philippines and a non-trading holding company in Singapore).

In this reporting year RYE 2025, we have continued from our foundation addressing the risk of modern slavery within our operations and supply chain going forward. 

The main development has been commencing integrating the anti-modern slavery assessment processes into the Datacom Group Risk Management Programme.  This will formalise the processes and enable the anti-modern slavery assessment and due diligence activities to be conducted and managed as part of a broader supply-chain risk management function.

Modern slavery is often the unseen global social evil for Australian and New Zealand companies.  Modern slavery can take many forms, and even in Australia, New Zealand and the other countries in which we operate, modern slavery still exists. Some of its forms include forced or compulsory labour, servitude, trafficking in persons, debt bondage, forced marriage, forced prison labour and child labour.

We oppose all forms of modern slavery practices and are committed to identifying, preventing, mitigating and remediating modern slavery impacts connected to our business and our supply chains.

In New Zealand we have continued to support the actions of World Vision who has been leading the vocal support from many large New Zealand businesses to encourage the New Zealand Government introduce similar legislation to that of the Modern Slavery Act.

We recognise that as a large purchaser and supplier of a diverse range of products and services, we must embed appropriate practices in our business and seek to work with suppliers who are aligned to our values.

Datacom works with organisations and communities around the world to solve their biggest challenges, imagine new possibilities, and help move them to a better place by connecting people and technology.

Built on strong local values, world-class technology, and experienced people who genuinely care, Datacom sets a new standard in IT services. Datacom supports customers through a broad range of services and solutions that span technology, operations, digital and products, all underpinned by robust industry experience and insight. We have people working across Australia, New Zealand and Asia, Datacom is truly world-class in capability, and proudly local at heart.

Datacom has a wide range of services and products including professional and technology management services, data centres, cloud services, integrated SaaS solutions, security systems offerings and management, hardware and software reselling, and contact centres. Often our customer selects the IT technology that we procure for on-supply. That means that although these suppliers are within our supply chain, we do not make the procurement decision. These suppliers are still subject to the same on-boarding procedures and risk assessment as suppliers we use ourselves.

As of 31 March 2025, Datacom employs around 6,100 people, with around 2,600 in Australia, over 3,200 people in New Zealand, and around 300 in Asia.

Most of Datacom’s businesses operate throughout Australia and New Zealand, with some technical and support operations in Malaysia (Kuala Lumpur) and the Philippines (Manila). We have a non-trading holding company for our Asian companies in Singapore.

Datacom Australia Holdings Pty Limited is a wholly owned subsidiary of Datacom Group Limited and operates the Australian business. All controlled entities within the Australian business are wholly owned by Datacom Australia Holdings Pty Limited. 

You can find further information about Datacom in our latest Annual Review.

We have on-boarded around 4,000 suppliers and partners globally. Our suppliers range from large vertically integrated global providers to small businesses, mainly based in Australia, New Zealand, Asia, the United States of America, the United Kingdom and the European Union.  

Our relationships include suppliers from the following sectors: technology, hardware and equipment, facilities management, waste management, office supplies, catering, cleaning, labour hire, professional services (business and technical consulting, legal and accounting) and marketing. We use these products and services in our business, and we also operate as a reseller of products and services such as software, technology infrastructure and associated hardware.

Our risk assessment and prioritisation of work focussed on the aspects we considered to be higher risk and then ensuring we could embed them into our procurement practices generally within Datacom. We have also paid greater attention to the modern slavery risks that would cause the greatest harm to individuals.

We continue to look at our internal operations and identified that our operations present the same risks we identified in our Anti-Modern Slavery Statement for previous years. We believe we have a low risk of modern slavery within our own workforce.

As part of this assessment, we paid particular attention to areas that could be higher risk such as operations outside New Zealand and Australia undertaken by businesses within the wider Datacom Group, recruitment practices and temporary workforce arrangements.

Most of our workforce are permanent employees and again most are in the higher skilled / wage bracket. Our employees are employed on contracts with standard terms allowing the employee to terminate their employment on notice and all employees are paid at or above the relevant minimum wage or other award or entitlement bands.

For any international recruited staff, we are an accredited employer in New Zealand and Australia and follow the strict VISA and immigration requirements in each country in which we operate. We have our own internal team looking at immigration issues, recruitment from international markets and security clearances / on-boarding of new staff.

We do use some contracted workers for certain customer engagements or staff augmentation assignments for customers. These contracted workers are employed by reputable third-party resource providers who then make their staff members available to us. These individuals tend to be highly skilled and there is a competitive market for their services in the technology sector. 

We also have independent contractors in our regular workforce. These are largely individuals with specialised skills or experience and are engaged as professional contractors at market rates. 

We also recognise that some of Datacom’s operations are in countries outside New Zealand and Australia which may be seen as higher risk geographies (particularly in Asia).

All our Asian businesses report directly into our Australia and New Zealand operations, so teams are formed across geographies and Datacom management has oversight of the whole workforce. 

This Reporting Year, we spent considerable time reshaping and reconfirming our employment practices, policies and procedures in all our Asian offices. This included employee feedback and discussions, new employment contracts and the launching of new Employee Handbooks for both Malaysia and the Philippines to meet local law requirements, but also to ensure we flowed down our Datacom commitment to staff and their well-being. This was led by the People & Culture team.

We are confident that our teams and procurement supply chains in Asia have a low risk of modern slavery.

We continue with our company-wide mandatory training in human rights and anti-modern slavery to all staff in our business (along with other ethical, security, privacy and business practice compliance).

For our supply chain, because of our supplier risk assessment outlined above, we identified very low risk suppliers through to those within a potentially higher-risk category. In the higher risk category, we identified suppliers of technology products and services (for both internal use and on-supply or resale to customers), cleaning, maintenance services, field services, application development services, construction and building works, freight, catering, security services, office supplies, waste management, temporary workforce augmentation and marketing products.

We also understand that our suppliers have their own suppliers, which may also connect us to modern slavery risk.

This Reporting Year we focused on trying to better understand this risk beyond our first-tier suppliers, by reviewing the next 50 of our top suppliers’ anti-modern slavery statements and policies where we did not have a response to previous requests for information from them. We have now completed a review of our top 100 suppliers.

We were able to identify and source public statements on anti-modern slavery, supply chain compliance and/or workplace policies from virtually all of this supplier group, less suppliers we no longer use. We are still following up with 7 suppliers as at 31 March 2025.

We are aware that some of our suppliers that provide IT hardware, for example with rechargeable batteries or use rare-earth materials, will have significant modern slavery risk in their supply chains. This is an area to continue to focus on.

We have had in place for over 6 years a good on-boarding process which applies to all new suppliers in Australia and New Zealand. This has worked well and produces a risk-based result depending on their responses. High-risk or non-compliant suppliers are then escalated to business for follow up, and if still unacceptable, we do not on-board that supplier.

As previously mentioned, our Human Rights Policy and Protected Disclosure Policy (“Whistleblower Policy”) specifically recognise the risk of modern slavery and encourages our employees, contractors, suppliers or any member of the communities in which we work to report and act on any modern slavery concerns. Where concerns are investigated and substantiated, we are committed to taking appropriate action.

The action that our senior management team has committed to, led by our Head of Legal & Commercial, is to promptly respond to any complaint or identified modern slavery issue or risk, working with the relevant supplier to manage that risk, try to remediate any harm caused, and agree processes to prevent from happening again. If cooperation is not forthcoming in a satisfactory manner, termination of the supplier contract may be warranted. Our preference, however, is to work with suppliers so that they can improve the conditions and rights of workers and require that those suppliers remediate any harm caused.

To date, we have not had any complaints of modern slavery or identified any actual issues in our supply chain partners.

We believe that we have effectively put in place the foundation to assess and mitigate the risks of modern slavery in our internal operations and supply chain.

We have raised awareness on this important topic and have added modern slavery risks into our annual compulsory training for all staff.  We have a well embedded process to assess and work with all new suppliers which has now been in place for over 6 years.  We have filled in the previous information gaps with all of our top 100 suppliers (by spend) in relation to how they are dealing with the risk of modern slavery in their operations. 

We intend to continue with our actions listed above, and importantly, continue to educate and train our business teams so they are alert to the risks. Our centralised Procurement Team plays a key role in this, and they are an important part of our anti-modern slavery approach. 

The plan in the next reporting year RYE 2026 to include the anti-modern slavery programme under our Group Risk Management Programme, and role out a new tool for supply-chain management, should improve our visibility and management of anti-modern slavery risks in our supply chain.

We understand this is not a static task but a programme of activity to continue over time. We will seek to continue to focus on the areas with the highest potential impact on people.

Datacom Australia Holdings Pty Limited owns 100% of our Reporting Entities, and Datacom Group Limited owns 100% of any Datacom Group company carrying on business in Australia. These entities operate as part a fully integrated business in Australia and part of the wider Datacom Group, with a central Datacom Group Board, centralised leadership team from all lines of business and a Datacom Group corporate support function that supports all lines of business (including People & Culture, Strategy & Risk, Property & Facilities, Procurement, Finance and Legal).

The consultation process included working with representatives of all lines of business dealing with procurement, human resources, business operations, sales and finance, risk and legal, to update this Statement.   

Individual Reporting Entities Directors, and the Group Leadership Team as a whole, were made aware of the anti-modern slavery programme, consulted on the programme’s planned content and application. They have fully supported the Group-wide adoption of our programme.