Modern Slavery and Ethical Sourcing Statement

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.

We treat every person who works for National Digital with dignity and respect. No engagement with us involves deception, threat, coercion or violence. We prohibit forced labour, child labour, involuntary labour and human trafficking in our own operations and in the work performed for us.

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 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 directly by us under a written agreement that sets their scope, their rate and their conduct obligations. Most of that workforce is in Australia, engaged as employees under the Fair Work framework or as Australian contractors. A small number of contractors are based overseas and are engaged on the same written terms. The second part is purchased services: cloud infrastructure, developer tooling and software subscriptions, concentrated in a small number of major vendors including Amazon Web Services, Google, Cloudflare 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

In our own operations the risk is low. Our workforce is small and engaged directly, with no labour hire intermediaries and no seasonal or itinerant workforce. We know every person who does work for us and we pay them ourselves. Australian workers are paid at or above Australian award and market rates. Where a contractor is based overseas we contract with them directly rather than through an agency, pay the rate set in their agreement, and hold the same conduct obligations over the work.

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 state the limit of our own visibility.

4. Actions taken to assess and address those risks

Supplier selection. We do not run a screening or audit programme over our vendors, and we are not in a position to audit a global cloud provider. What we do before committing to a significant supplier is make a reasonable effort to establish that they publish a modern slavery statement or equivalent policy of their own, and we prefer suppliers that do. Our principal vendors report under the Australian or United Kingdom regimes and their statements are public.

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 are set in their written agreement at market levels for the work, and we do not price client work in a way that depends on pushing those rates down.

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. We would end the supplier relationship after taking those steps, because exiting first leaves the affected workers where they were.

5. How we assess effectiveness

We do not run an assurance programme with audits and scoring. We assess effectiveness against four things we can verify each year: that every person engaged during the year worked under a written agreement held directly with us; that every significant new supplier was checked for a published modern slavery statement before we committed to them; 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.