Modern Slavery and Ethical Sourcing Statement

National Digital — The Trustee for Australian Business Trust, ABN 13 744 838 758

1. Purpose and scope

This statement sets out how National Digital identifies and manages the risk of modern slavery in
our operations and our supply chain, and the standards we apply to the people and businesses we
engage.

National Digital is not a reporting entity under the Modern Slavery Act 2018 (Cth). The Act
applies to entities with annual consolidated revenue of at least $100 million, and our revenue is
well below that threshold. The Australian Government's 2024 response to the statutory review of
the Act retained the $100 million threshold, so we do not expect to come into scope in the near
term.

We publish this statement voluntarily, and we have written it against the reporting criteria in
section 16 of the Act so that a client or purchaser assessing us can compare our disclosure
against the same framework a reporting entity uses. It covers National Digital's whole operation:
the trust, the trustee company, our employees, and every contractor we engage.

2. Our structure, operations and supply chain

National Digital is an Australian software consultancy based at Burleigh Heads in Queensland,
operating as The Trustee for Australian Business Trust, ABN 13 744 838 758. The trustee company is
General Consulting Services Pty Ltd, ACN 658 447 280, registered in Queensland.

We design, build, integrate, host and maintain custom software. We operate remote-first with a
small workforce in Queensland and Victoria, supported by a bench of Australian specialist contract
engineers engaged per project. We manufacture nothing, we hold no inventory, and we operate no
physical distribution.

Our supply chain has two parts. The first is labour: every person who performs work for National
Digital is engaged in Australia, either as an employee under the Fair Work framework or as an
Australian contractor under a written agreement. The second is purchased services: cloud
infrastructure, software subscriptions and professional services, concentrated in a small number
of major vendors including Amazon Web Services, Microsoft and GitHub. Each of those vendors
publishes its own modern slavery statement under the Australian or United Kingdom regimes.

3. Risks of modern slavery practices

We describe our risk as we find it rather than describing a programme we do not run.

In our own operations the risk is low. Our workforce is small, Australian, engaged directly,
and paid at or above Australian award and market rates. There are no labour hire intermediaries,
no offshore employment arrangements and no seasonal or itinerant workforce. We have visibility of
every person who does work for us.

In the first tier of our supply chain the risk is low. Our direct suppliers are large
technology and professional services companies operating in jurisdictions with modern slavery
reporting obligations, and they are selected on capability rather than on price pressure that
might drive labour cost down.

Beyond the first tier the risk is real and our leverage is limited. The cloud infrastructure we
buy depends on data centre construction and on hardware manufacturing, and the electronics supply
chain carries documented risks of forced labour several tiers upstream of any contract we hold.
The devices our own team works on carry the same risk. We cannot audit those tiers and we do not
claim to. What we can do is choose vendors that report on those risks and disclose the limit of
our own visibility, which is what this section does.

4. Actions taken to assess and address those risks

Supplier screening. New suppliers are screened before engagement. We ask about their workforce
arrangements, whether they are a reporting entity under the Act, and whether they publish a modern
slavery statement. Where a supplier's answers raise a concern, we do not engage them. An existing
supplier whose circumstances materially change is reassessed.

Contractual obligations. Contractors are engaged under written agreements requiring compliance
with Australian workplace law and prohibiting the use of forced labour, child labour or
involuntary labour in the performance of the work. The same obligations pass down to any
subcontractor.

Pay and conditions. We do not compete on labour cost. Rates paid to contractors sit at
Australian market levels, and our published client rate card has a floor below which we do not
quote, so there is no commercial pressure in our own pricing that could be transmitted into labour
conditions.

Training and awareness. Modern slavery and ethical sourcing awareness forms part of induction
for all National Digital personnel and is refreshed annually alongside our privacy and information
security material.

Raising a concern. Any person engaged by National Digital, and any person working in our supply
chain, may raise a concern about modern slavery, labour exploitation or unethical conduct directly
with the Chief Executive Officer at cameron@nationaldigital.com.au or, where the concern involves
the Chief Executive Officer, with the Chief Operating Officer. Concerns may be raised anonymously.
Every report is investigated, the outcome is recorded, and no person who raises a concern in good
faith is disadvantaged for doing so. Where a report discloses conduct that may be unlawful, we
refer it to the appropriate authority.

Remediation. If we identified modern slavery in our operations or supply chain, our first
obligation would be to the people affected. We would act to stop the harm, support access to
remedy, and report to the relevant authority. Ending a supplier relationship is a step we would
take after those things, not instead of them, because exiting quietly leaves the affected workers
where they were.

5. How we assess effectiveness

At our size, an assurance programme with audits and scoring would be theatre. We assess
effectiveness against four things we can actually verify each year: that every person engaged
during the year was engaged in Australia under a written agreement; that every new supplier was
screened before engagement; that induction and annual refresher training was completed by all
personnel; and that every concern raised was investigated and closed with a recorded outcome.

This statement is reviewed annually, and sooner if our operations, workforce arrangements or
supply chain change materially.

6. Consultation and approval

National Digital does not own or control any other entity, so there are no entities to consult
under section 16(1)(f) of the Act. This statement was approved by Cameron Young as Chief Executive
Officer of National Digital and director of the trustee company on 9 September 2026.