‍

‍

‍

FORTUNA IDENTITY PTY. LTD.

MODERN SLAVERY POLICY

Document Title: Modern Slavery Policy
Policy Owner: Board of Directors
Version: 1.0
Effective Date: July 2026
Review Date: June 2027
Approved By: Board of Directors, Fortuna Identity Pty. Ltd.

1. PURPOSE

Fortuna Identity Pty. Ltd. ("Fortuna", "Company", "we", "our", or "us") is committed to conducting its business ethically, responsibly, and with integrity. We maintain a zero-tolerance approach to modern slavery in all its forms and are committed to identifying, preventing, mitigating, and addressing modern slavery risks within our operations and supply chains.

This Policy establishes the principles, responsibilities, and procedures adopted by the Company to ensure compliance with applicable laws, including the:

• Modern Slavery Act 2018 (Cth);

• Fair Work Act 2009 (Cth);

• Work Health and Safety Act 2011 (NSW);

• Anti-Discrimination Act 1977 (NSW);

• Privacy Act 1988 (Cth);

• Any other applicable Australian laws and regulations.

2. SCOPE

This Policy applies to:

• Directors;

• Officers;

• Employees;

• Contractors;

• Consultants;

• Temporary staff;

• Labour hire personnel;

• Interns;

• Volunteers;

• Suppliers;

• Vendors;

• Service providers;

• Business partners and any other persons acting on behalf of the Company.

The Company expects all persons associated with its business to adhere to the principles set out in this Policy.

3. POLICY STATEMENT

Fortuna prohibits and will not tolerate any form of:

• Human trafficking;

• Forced labour;

• Compulsory labour;

• Debt bondage;

• Servitude;

• Slavery;

• Child labour;

• Deceptive recruitment practices;

• Exploitative labour practices;

• Retention of identity documents;

• Withholding of wages;

• Restriction of workers' freedom of movement.

The Company is committed to ensuring that its operations and supply chains are free from modern slavery and labour exploitation.

4. DEFINITION OF MODERN SLAVERY

For the purposes of this Policy, modern slavery includes conduct that would constitute:

• Slavery;

• Servitude;

• Forced labour;

• Debt bondage;

• Human trafficking;

• The worst forms of child labour;

• Forced marriage;

• Deceptive recruiting for labour or services.

Modern slavery may occur in any industry, sector, or geography and can affect both direct and indirect workers.

5. GUIDING PRINCIPLES

The Company is committed to:

1. Respecting internationally recognised human rights;

2. Maintaining fair and lawful employment practices;

3. Preventing labour exploitation;

4. Conducting business ethically and transparently;

5. Assessing and addressing modern slavery risks;

6. Taking appropriate action where risks or incidents are identified;

7. Promoting responsible sourcing practices.

6. EMPLOYMENT PRACTICES

Fortuna shall:

• Ensure all work is voluntary;

• Prohibit forced, bonded, or involuntary labour;

• Prohibit the confiscation of passports or identity documents;

• Pay employees in accordance with applicable laws;

• Ensure employees are free to terminate employment subject to lawful notice requirements;

• Verify legal work rights;

• Maintain written employment agreements;

• Prohibit child labour.

No recruitment fees or unlawful charges shall be imposed upon workers.

7. SUPPLY CHAIN COMMITMENT

The Company recognises that modern slavery risks may arise within supply chains.

Accordingly, Fortuna shall:

• Conduct appropriate due diligence on suppliers and contractors;

• Assess suppliers for labour and human rights risks;

• Include contractual obligations requiring compliance with anti-slavery laws;

• Require suppliers to cooperate with investigations;

• Periodically review supplier compliance;

• Take appropriate action where unacceptable risks are identified.

8. SUPPLIER EXPECTATIONS

Suppliers and business partners are expected to:

1. Comply with all applicable labour laws;

2. Prohibit modern slavery practices;

3. Maintain lawful employment conditions;

4. Ensure fair wages and working hours;

5. Maintain grievance mechanisms;

6. Permit reasonable due diligence and audits;

7. Promptly report any suspected modern slavery concerns.

Failure to comply may result in suspension or termination of the business relationship.

9. MODERN SLAVERY RISK ASSESSMENT

The Company shall periodically assess risks of modern slavery, including risks relating to:

• Geographic location;

• Industry sector;

• Labour-intensive activities;

• Use of labour hire arrangements;

• Outsourcing arrangements;

• High-risk suppliers;

• Procurement practices.

Risk assessments may include:

• Supplier questionnaires;

• Compliance certifications;

• Contractual reviews;

• Audits;

• Desktop assessments;

• Public information reviews.

10. DUE DILIGENCE PROCEDURES

The Company may undertake reasonable due diligence measures, including:

Before Engagement

• Supplier screening;

• Background verification;

• Review of policies and practices;

• Assessment of labour standards.

During Engagement

• Periodic reviews;

• Supplier declarations;

• Compliance certifications;

• Risk monitoring.

Where Risks are Identified

• Additional enquiries;

• Corrective action plans;

• Enhanced monitoring;

• Suspension or termination of the relationship.

11. REPORTING CONCERNS

All employees and third parties are encouraged to report any actual or suspected incidents of modern slavery.

Reports may be made to:

• Immediate Supervisor;

• Human Resources;

• Compliance Officer;

• Senior Management;

• Whistleblower Reporting Channel.

Reports may be made confidentially and, where permitted by law, anonymously.

The Company prohibits retaliation against any person who raises a concern in good faith.

12. INVESTIGATION AND REMEDIATION

Where a potential instance of modern slavery is identified, the Company may:

• Conduct an investigation;

• Engage external advisers where appropriate;

• Implement corrective measures;

• Require supplier remediation;

• Suspend business relationships;

• Terminate contracts where necessary;

• Report matters to relevant authorities where legally required.

Where appropriate, the Company shall consider measures to support affected individuals.

13. TRAINING AND AWARENESS

The Company shall provide appropriate training and awareness programmes regarding:

• Modern slavery risks;

• Reporting obligations;

• Supplier due diligence;

• Ethical sourcing practices.

Training may be provided to:

• Employees;

• Management;

• Procurement personnel;

• Relevant contractors.

14. RESPONSIBILITIES

Board of Directors

The Board shall:

• Oversee the Company's approach to modern slavery;

• Review significant risks;

• Approve any Modern Slavery Statements required by law.

Senior Management

Senior Management shall:

• Implement this Policy;

• Ensure adequate resources are available;

• Promote a culture of ethical business conduct.

Employees

Employees shall:

• Comply with this Policy;

• Report concerns;

• Participate in training where required.

Suppliers

Suppliers shall:

• Comply with applicable anti-slavery laws;

• Cooperate with due diligence activities;

• Promptly report actual or suspected breaches.

15. MODERN SLAVERY STATEMENTS

Where required under applicable law, the Company shall prepare and publish a Modern Slavery Statement that addresses:

• The Company's structure and operations;

• Modern slavery risks;

• Actions taken to assess and address risks;

• Effectiveness of those actions;

• Consultation processes;

• Other information required by law.

16. BREACH OF THIS POLICY

Any employee who breaches this Policy may be subject to disciplinary action, including termination of employment.

Any supplier, contractor, or business partner that breaches this Policy may be subject to:

• Corrective action requirements;

• Suspension of services;

• Termination of contractual arrangements;

• Reporting to regulatory authorities where appropriate.

17. REVIEW OF POLICY

This Policy shall be reviewed:

• At least annually;

• Following material legislative changes;

• Following significant modern slavery incidents;

• As otherwise determined by the Board.

18. RELATED DOCUMENTS

This Policy should be read together with:

• Code of Conduct;

• Labour Policy;

• Whistleblower Policy;

• Supplier Code of Conduct;

• Procurement Policy;

• Equal Employment Opportunity Policy;

• Privacy Policy;

• Grievance Procedure.

Approved By: Board of Directors
Fortuna Identity Pty. Ltd.

Effective Date: July 2026

Review Date: June 2027

Version: 1.0

‍

‍