Modern Slavery Policy

1. Introduction

Resilia, part of the Wellbeing Solutions Group (hereinafter referred to as “The Group, we, our”) is dedicated to prevent modern slavery and human trafficking within our operations, supply chains, and business relationships in accordance with the Modern Slavery Act 2018 (Cth).

2. Modern Slavery Statement

Wellbeing Solutions Group is committed to operating ethically and transparently, enforcing effective controls to prevent modern slavery, partnering only with suppliers who uphold human rights, and continuously review and improve our practices to identify and address modern slavery risks.

3. Scope

This policy is applicable to all departments and users of The Group including:

• All employees (permanent, casual or subcontractors)
• All business operations within Australia; and
• All suppliers, 3^rd party vendors, and partners who provide goods or services to or on behalf of the Group.

4. Definitions

As defined under the Moderna Slavery Act 2018 (Cth), Modern Slavery refers to conduct that would constitute:

• Trafficking in persons
• Slavery or servitude
• Forced labour
• Debt bondage
• Deceptive recruitment for labour or services
• The worst forms of child labour

5. Embedding this Policy into Business Operations

The Group regularly reviews and assesses our key supplier of goods and services. We are aware that tackling modern slavery requires everyone to play a part and remain vigilant to the risk in all aspects of Group businesses and work relationships.

a. Our Operations

• We follow best practices in our recruitment process, from selection to job offer
• We have proper documentation of our staff, to ensure they meet all essential requirements for the role
• We have position descriptions for all our job roles, so there is clarity on the demands and expectations of the job
• We ensure wages meet legal requirements for minimum wages and are aligned with the prevailing sector wage
• All workers, including migrant workers, can cancel their work contracts at any time with no financial penalty, subject to giving reasonable notice in accordance with local law or a collective agreement
• We prohibit The Group or suppliers withholding any worker identity or immigration documents as well as only use recruiters that comply with local labour laws.

b. Our Suppliers

• We conduct risk assessments to determine which parts of the supply chains are most at risk from modern slavery so efforts can be focused on those aspects
• We require our suppliers to complete a modern slavery risk assessment prior to onboarding and at least annually as part of their ongoing supplier engagement
• Our contractual documentation and procurement procedures incorporate prohibition against slavery or servitude, as well as the use or trafficked and child labour
• We have provisions for our contracted suppliers to hold their own suppliers and supply chain to the same standards
• We reserve the right to terminate any contractual agreement is there is a breach

With our suppliers predominantly based in Australia, we believe they have a lower risk of modern slavery as they will also be required to comply with the Modern Slavery Act within their operations and their own supply chains.

6. Roles and Responsibilities

7. Training and Awareness

The Group ensures relevant staff receive adequate training on this policy and any supporting processes applicable to their role, especially if they work closely with external stakeholders.  Employee awareness will be strengthened through online training and imparting knowledge relating to:

• Recognising signs of modern slavery
• Reporting and escalation procedures including:
  • Directly to a supervisor or manager
  • Anonymously via the Whistleblower channel [email protected]
  • Directly to the CFO [email protected]
• Ethical procurement and supplier engagement practices
• The requirements of the Modern Slavery Act 2018 (Cth)

8. Breaches

Breaches of this policy may result in disciplinary action, termination of contracts, or reporting to appropriate authorises in accordance with Australian law.

9. Monitoring and Continuous Improvement

This policy will be reviewed annually or as required by legislation, and Modern Slavery Statement updated to reflect progress and any identified risk.  We will continue to evaluate the effectiveness of our risk management and due diligence processes.

Reviewed: 22 July 2025