Modern slavery policy

Purpose

Davidson Group (Aust) Pty Ltd (ACN 167 652 155) and its Related Bodies Corporate (as defined under the Corporations Act 2001 (Cth) are committed to respecting human rights and eradicating all forms of modern slavery in our operations and supply chains.

Scope

This Policy applies to all Davidson entities, employees, contractors, consultants, suppliers, and third-party partners (domestic and offshore).

Commitment

Davidson acknowledges that modern slavery is a complex global issue requiring collective commitment, transparency and effective risk-based action. Davidson complies with the Modern Slavery Act 2018 (Cth) and aligns its approach with recognised international standards, including the UN Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Business Conduct. Davidson also monitors international regulatory developments, including mandatory human rights due diligence and forced labour regimes in other jurisdictions, and will continue to strengthen its policies, governance and due diligence practices to ensure they remain proportionate, effective and responsive to evolving expectations.

Definition and Risk Context

Modern slavery, as defined in the Modern Slavery Act 2018 (Cth) and including any offence under Division 270 or 271 of the Criminal Code Act 1995 (Cth) or any equivalent offence under applicable law, includes:

· slavery and servitude

· forced labour and debt bondage

· human trafficking

· forms of child labour

· deceptive recruiting and slavery-like practices (e.g. forced marriage)

Key risk areas for professional services include:

· engagement of contractors, consultants or labour hire firms, particularly in high-risk jurisdictions

· outsourcing of services like bookkeeping, IT support, or facilities management to regions with weak labour protections

· procurement of office equipment, technology or supplies from manufacturers in high-risk jurisdictions

· complex, multi-jurisdictional supply chains with limited visibility of subcontractor practices

Our Approach

Legal Compliance

We comply with all relevant, labour, immigration, and modern slavery legislation in every jurisdiction in which we operate or engage suppliers.

Where offshore suppliers or partners are utilised, Davidson requires compliance with equivalent human rights and labour standards consistent with the Modern Slavery Act 2018 (Cth), and other internationally recognised conventions.

Davidson prepares and publishes an annual joint Modern Slavery Statement in accordance with the Modern Slavery Act 2018 (Cth). It covers Davidson Group (Aust) Pty Ltd and its Related Bodies Corporate, each named in the Statement. If another jurisdiction’s law requires a Related Body Corporate to publish its own separate modern slavery statement, it must do so. Otherwise, that entity is covered by this joint Statement and must follow this Policy (or a local policy that meets the same standard).

Supplier Engagement and Risk Management:

All suppliers must:

· comply with the Modern Slavery Act and our ethical sourcing expectations

· maintain accurate employment and sub-contractor records for seven (7) years

· permit audit or verification by Davidson or an independent reviewer

· demonstrate compliance with applicable local laws and international human rights standards if operating offshore

Contracts must include:

· compliance and termination clauses relating to modern slavery

· cooperation obligations for investigations or audits

· obligations to notify Davidson of any identified or suspected modern slavery risk in their operations or supply chain

Due Diligence and Risk Assessment

Davidson undertakes supplier due diligence using a risk-based approach supported by its Modern Slavery Supply Chain Due Diligence Standard Operating Procedure. This includes identifying higher-risk suppliers, assessing modern slavery risks, implementing appropriate due diligence measures, recording outcomes and monitoring suppliers over time.

Annual risk assessments establish KPIS such as:

· number of employees completing training

· response times to reported concerns

· remediation completion rates

Awareness and Capacity Building

All employees receive mandatory modern slavery training annually; enhanced guidance is provided to procurement, HR and legal teams.

Governance and Accountability

· The General Counsel is responsible for oversight of Davidson's Modern Slavery framework and associated due diligence processes.

· The Risk & Compliance Partner coordinates supplier due diligence activities and maintains the Modern Slavery Supplier Register.

· The Modern Slavery Work Group supports implementation, continuous improvement, awareness and monitoring activities across the business.

· The CEO and Risk Committee receive updates on material modern slavery risks and remediation activities.

· The Board oversees the effectiveness of the framework and approves the annual Modern Slavery Statement.

The policy is reviewed annually or as required by legislative change.

Reporting and Whistleblower Protections

Davidson’s Whistleblower Policy applies to all modern slavery reports, including those relating to offshore operations or suppliers.

Internal Reporting: Concerns should be reported to the General Counsel; initial response within two (2) business days.

External Reporting: Call 000 if someone is in immediate danger.

Protections: Confidential reporting channels, no retaliation, secure record-keeping and support services for affected persons.

Remediation and Consequences: Where modern slavery is identified or reasonably suspected, Davidson will take proportionate remedial action, which may include supporting affected persons, requiring supplier corrective action, terminating employment or supplier engagements, and referring matters to law enforcement or relevant authorities. Breach of this Policy by an employee, contractor or supplier may result in disciplinary action up to and including termination.

Transparency and Continuous Improvement

Davidson reviews its modern slavery risk management framework annually and updates its controls, supplier due diligence and contractual standards in response to legislative reform, guidance from the Australian Anti-Slavery Commissioner, and developments in international best practice, including consideration of global regulatory trends that signal a shift toward mandatory, risk-based human rights due diligence and enforcement measures. Any enhancements are implemented in a manner that is proportionate to Davidson's operations, risk profile and business model.