Modern Slavery Policy
1. Purpose
Honey Group and its affiliated companies are committed to conducting business ethically and
responsibly. We have zero tolerance for modern slavery, human trafficking, forced labour, child
labour, servitude and other forms of exploitation within our operations and supply chains.
This Policy establishes Honey Group’s commitment to preventing modern slavery, complying
with the Modern Slavery Act 2018 (Cth), protecting human rights, and promoting ethical labour
practices throughout our business.
2. Scope
This Policy applies to all Honey Group entities, directors, employees, contractors, labour hire
personnel, consultants, suppliers, manufacturers, distributors, agents and business partners
operating in Australia and internationally. It applies across all business activities including
procurement, manufacturing, warehousing, logistics, sales, installation and support services.
3. Definitions
- Modern Slavery: Includes slavery, servitude, forced labour, debt bondage, deceptive
recruiting, child labour, human trafficking and other exploitative practices. - Supplier: Any organisation providing goods or services to Honey Group and/or its related
entities. - Supply Chain: All organisations, labour and services contributing to Honey Group (and/or
related entities) products or services.
4. Policy Statement
Honey Group will:
- Maintain zero tolerance towards modern slavery.
- Conduct business fairly, ethically and lawfully.
- Respect internationally recognised human rights.
- Identify and manage modern slavery risks within operations and supply chains.
- Expect suppliers to maintain equivalent ethical standards.
- Refuse to knowingly engage suppliers involved in exploitative labour practices.
5. Responsibilities
Executive Management
- Provide leadership, resources and oversight for implementation.
- Review the effectiveness of this Policy annually.
Procurement
- Undertake risk-based supplier due diligence before onboarding and periodically thereafter.
- Assess suppliers operating in higher-risk countries or industries.
- Require suppliers to comply with Honey Group’s Terms & Conditions of Purchase.
- Maintain supplier due diligence records.
Managers
- Promote awareness within their teams.
- Investigate reported concerns promptly.
- Implement corrective actions where required.
Employees
- Complete required training.
- Comply with this Policy.
- Immediately report suspected modern slavery.
6. Supplier Due Diligence
Honey Group will apply a risk-based due diligence process that may include supplier
questionnaires, assessment of country and industry risk, contractual commitments, review of
labour practices, and corrective action plans where required. Suppliers identified as presenting
unacceptable risk may be suspended or removed.
7. Reporting
Any employee, contractor or supplier who suspects modern slavery must report the matter
immediately to management. Reports will be treated confidentially where possible, investigated
promptly and without retaliation against the person making the report in good faith.
8. Non-Compliance and Remediation
Where modern slavery risks or breaches are identified, Honey Group will investigate the matter,
work with the supplier or affected party to implement corrective actions, monitor progress and,
where necessary, suspend or terminate the business relationship.
9. Training and Awareness
Honey Group will provide periodic training for employees involved in procurement, supplier
management, manufacturing and quality. Awareness material may also be provided to suppliers
and contractors.
10. Monitoring
Honey Group will monitor the effectiveness of this Policy through supplier assessments, internal
audits, training completion records, corrective action monitoring and periodic management
review.
11. Review
This Policy will be reviewed at least annually, or earlier where legislation, business operations
or identified risks require amendment.
Authorised by
Glenn Honey
Chief Executive Officer
22 July 2026