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This Anti-Modern Slavery Statement (AMS Statement) is made in accordance with the Modern Slavery Act 2018 (Cth) for the reporting year ending on 31 March 2026 (RYE 2026) by Datacom Australia Holdings Pty Limited (ABN 45 094 235 373) and its Reporting Entities[1] (jointly Datacom).
This is now our seventh AMS Statement.
Datacom continues to take the issue of modern slavery seriously. We have continued to extend our reporting to include all the companies owned and controlled by Datacom Group Limited (our parent company in New Zealand). This also includes all our companies that we own in both New Zealand and Asia (Malaysia, the Philippines and a non-trading holding company in Singapore).
In this reporting year RYE 2026, we have continued to address the risk of modern slavery within our operations and supply chain going forward. The main development has been the completion of the integration of the anti-modern slavery assessment processes into the Datacom Group Risk Management Programme. This has formalised the processes and enabled the anti-modern slavery assessment and due diligence activities to be conducted and managed as part of a broader supply-chain risk management function.
We adopt a pragmatic due diligence system to help assess and manage modern slavery risks within our business. We focus on:
We have a good on-boarding process for all of our suppliers. This gives us the ability to raise not only modern slavery issues, but also other Human Rights issues, ethical approaches to business and security / privacy policies. We are also rolling out automated tools to assist in auditing and assessing ongoing compliance.
All suppliers are subject to our Partner Code of Conduct – available on our website. We also consider and review our supplier’s equivalent codes where they have these in place. We also have internal policies and a Code of Conduct for our staff as discussed below in our “ESG approach” section. We have also published our Datacom Human Rights Policy on our website
Our People & Culture Team (which includes recruitment) maintain policies, procedures and practices to ensure our internal workforce remains at a low risk of modern slavery. Our Group Risk Management Team has oversight over anti-modern slavery, and our central procurement team manages and evaluates modern slavery risks with our suppliers. Our central procurement team is currently being restructured, which will be completed in RYE 2027.
We continue to include Human Rights and anti-modern slavery issues within our compulsory annual training for all staff. We have a dedicated intranet page with all information and resources in one place for our staff. We have at least annual reminders to staff about the importance of anti-modern slavery.
To date, we have not identified an actual modern slavery event in our internal operations or supply chain.
In this Reporting Year (RYE 2026) we have reported, for the first time, under the mandatory climate-related financial disclosures. These are being phased in from January 1, 2025, under the Australian Sustainability Reporting Standards (ASRS) and the Corporations Act 2001, and require comprehensive reporting on climate-related financial information, including risks, opportunities, and greenhouse gas (GHG) emissions. Australia's new ESG reporting requirements are designed to promote transparency and accountability on climate-related risks and opportunities for businesses and financial institutions. They do not necessarily have an impact on modern slavery issues.
However, on our website are various social and community initiatives we have been involved with. These are also well summarised in our Annual Review which we publish each year on our website
Our approach to ESG is very much linked to our core values and purpose to make a difference in people’s lives by turning the imaginable into reality:
And this is also reflected in our commitment in respect of anti-modern slavery in our Code of Conduct - which all staff must follow:
"We will seek mutually beneficial relationships with suppliers and recognise our position can significantly influence their practices. As such, we will aim to promote sustainable, ethically and fairly trading. Contracts signed with suppliers must be honoured.
We are opposed to and will oppose all forms of modern slavery (this includes things like forced or compulsory labour, servitude, prison, trafficing in persons, debt bondage, forced marriage, prison labour and child labour) - both within our operations and our supply chain. We require our suppliers to agree to respect human rights and to take reasonable steps to ensure that they are not complicit in human rights impact, including modern slavery. We will put in place adequate procedures to manage the risk of modern slavery within our supply chain."
This approach is also enshrined in our Datacom Human Rights Policy, where we commit that we will:
Our Datacom Human Rights Policy has been published on our website this reporting year (RYE 2026).
We also have a whistleblowing complaint system, where any employee, contractor, supplier or even a member of the public, may raise an issue or suspected issue in confidence using the Datacom Group Protected Disclosure (‘Whistleblowing’) Policy. Further information regarding the investigation process is publicly available in the Whistleblower Policy on our website.
To date, no complaints concerning modern slavery issues have been received.
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 major bipartisan effort to put into legislation the Modern Slavery Bill which was introduced to the New Zealand Parliament in February 2026. It has the support of Labour and National and may become law this calendar year.
The Bill is still in draft, but should it become law in its present form, it would introduce a similar anti-modern slavery regime as in Australia in terms of reporting obligations. The material differences to the Australian requirements at this stage include introducing several key enhancements, most notably a comprehensive enforcement regime with criminal and civil penalties; director liability; and potential government procurement exclusions. Many of these enhancements reflect recommendations that came out of the 2023 Australian statutory review into Australia’s Modern Slavery Act 2018 (Cth).
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 help them with their challenges, imagine new possibilities, and help move them to a better place by connecting people and technology.
Datacom is built on strong local values, world-class technology, and experienced people who genuinely care. 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 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 customers select 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 2026, Datacom employed 5,945 people, with around 2,500 in Australia, around 3,100 people in New Zealand, and around 345 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 with more about our operations and business on our website.
We currently have an on-boarded around 2,900 suppliers and partners. 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 attention to the modern slavery risks that would cause the greater 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 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 internationally 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 also follow all immigration requirements for employment in our Asian offices (the Philippines and Malaysia). 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.
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). This includes all our people managers.
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 third tranche of 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 150 suppliers, which represents over 90% of our total spend.
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 also previously talked directly with staff and management at our suppliers in Asia (Philippines and Malaysia) responsible for cleaning, maintenance services, property, facilities, local tech supply, security, catering, and administrative duties. We are comfortable there is a low risk of modern slavery from these suppliers.
We have in place 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.
In RYE 2027 we will extend this on-boarding process to suppliers based in Asia.
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 both our Head of Legal & Commercial and Director of Strategy & Risk, 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 embedded modern slavery risks into our annual compulsory training for all staff. We have a well-established process to assess and work with all new suppliers which has now been in place for over 7 years. Where possible we have filled in the previous information gaps with all of our top 150 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. As we have had an internal restructure of this team towards the end of RYE 2026, in RYE 2027 we will focus on training and upskilling the new members of the team to ensure they are across anti modern slavery risks, continue to operate the on-boarding process effectively, and identify any risks that they perceive in their day-to-day operations with our suppliers.
The plan in the next reporting year RYE 2027 is also to roll out the new tool for supply-chain management that we trailed this year, which 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.
This Statement has been approved by the Board of Directors of Datacom Australia Holdings Pty Limited for itself and each of the Reporting Entities on 23 June 2026.
Mark Hile – Managing Director
DATACOM AUSTRALIA HOLDINGS PTY LIMITED
DATACOM GROUP LIMITED also approve this statement on behalf of the Board of Datacom Group Limited, and its related subsidiary companies.
Tony Carter – Chair
DATACOM GROUP LIMITED
[1] Our Reporting Entities are companies owned or controlled by Datacom Australia Holdings Pty Limited or companies in the Datacom Group carrying on business in Australia, being Datacom Data Centres Pty Limited (ABN 58 110 978 179), Datacom Systems (AU) Pty Limited (ABN 39 135 427 075), Datacom Connect Pty Limited (ABN 16 103 112 303), Datacom Solutions (AU) Pty Limited (ABN 16 168 988 636), Datacom Security Pty Limited (ABN 67 679 834 363), Datacom New Zealand Limited (a New Zealand incorporate company, ABN 95 875 120 116), Datacom Systems Limited (a New Zealand incorporate company, ABN 84 189 277 546), and Datacom Solutions Limited (a New Zealand incorporate company, ABN 85 812 565 504). The New Zealand companies are assessed on an annual basis to determine if they are carrying on business in Australia according to ATO guidelines and are considered a Reporting Entity should they qualify.