At Veraspec, we prioritise safety and quality in all our operations. Our team is committed to ensuring that our high-rise building facade inspection, repair, glazing, and cleaning services are accessible and efficient. We adhere to industry standards and regulations to provide a superior service experience.

Modern Slavery Policy

1. Purpose of this policy

Veraspec is committed to respecting human rights and limiting the risks of modern slavery practices in our business operations and supply chains in Australia, the United Arab Emirates (UAE), and any other country in which we operate.

This policy sets out our expectations of employees, officers, contractors, labour-hire staff, suppliers, and other business partners in identifying, preventing, and responding to modern slavery risks.

2. Who this policy applies to

This policy applies to anyone involved in our business, including:

Employees, directors, and officers
Labour hire staff and agency workers
Contractors, consultants, and subcontractors
Suppliers and other third parties in our operations and supply chain

Although this policy is not part of any contract you may have with us, you are expected to comply with it. Failure to do so may result in disciplinary action (including termination of employment) and/or the ending of our business relationship, in line with applicable laws and contracts.

3. What is modern slavery?

Modern slavery is the deprivation of a person’s freedom for commercial gain, in violation of their fundamental human rights.

It involves situations where offenders use coercion, threats, or deception to exploit people and undermine their freedom. It can take many forms, including:

Slavery – owning or trading in people, including human trafficking
Forced labour and servitude – forcing a person to work under threat or coercion, or where their freedom is significantly restricted
Forced marriage – a marriage entered into without free and full consent
Debt bondage – requiring a person to work to repay a debt where the value of the work is not properly credited or the terms are unclear or exploitative
Deceptive recruiting – charging recruitment fees, confiscating identity documents, or misleading workers about their conditions or freedom to leave a job
Exploitative child labour – work that exploits children, interferes with their education, or exposes them to unsafe conditions

Modern slavery is different from poor working conditions or underpayment (which may still be unlawful for other reasons), but in practice the issues can overlap.

4. Indicators of modern slavery practices

Modern slavery can be complex and difficult to identify. Indicators may include situations where a person:

Does not have possession of their own passport, ID, or travel documents
Appears to be instructed or coached by someone else, or allows others to speak for them
Is dropped off and collected from work by the same person
Appears withdrawn, frightened, or shows unexplained injuries
Cannot freely contact friends or family, or has very limited social interaction
Has a story that contains obvious inconsistencies
Has few personal possessions or limited control over their finances or bank account
Lives in very poor, overcrowded, or employer‑controlled accommodation

These indicators are not exhaustive and do not necessarily mean modern slavery is occurring, but they may signal that something is wrong and warrants further attention.

5. Why we are addressing modern slavery risks

Limiting modern slavery risks makes good business sense, protecting people in our operations and supply chain and supporting our reputation as an ethical business.

It also supports our obligations under relevant laws and guidance, including the Australian Modern Slavery Act 2018 (Cth) (where applicable) and relevant UAE laws on human trafficking and forced labour.

Where required by law (for example, if Veraspec meets mandatory reporting thresholds), we will prepare and publish modern slavery statements describing how we assess and address modern slavery risks in our operations and supply chains.

6. Your responsibilities

You must take reasonable steps to help ensure that our business and supply chain are free from modern slavery practices.

Regardless of your role or seniority, you are expected to:

Participate in relevant training on this policy and modern slavery awareness
Make appropriate checks on employees, recruitment agencies, and key suppliers consistent with our procurement and HR procedures
Pay close attention to higher‑risk areas, particularly procurement, outsourcing, labour hire, cleaning, security, construction, and sourcing from countries or sectors with elevated risk indicators
Remain alert to possible indicators of modern slavery (see section 4) and raise concerns promptly
Use only approved contracts that contain modern slavery clauses where required
Follow any instructions or procedures issued by Veraspec in relation to modern slavery risk assessment, due diligence, and remediation

Turning a blind eye is not acceptable. If you reasonably suspect that modern slavery may be occurring in our operations or supply chain, you must report it in accordance with this policy.

7. Our approach to managing modern slavery risks

Veraspec will take a risk‑based approach to identify, assess, and address modern slavery risks in our operations and supply chains, including:

Conducting due diligence on higher‑risk suppliers, contractors, and labour‑hire providers
Incorporating modern slavery requirements into relevant contracts and supplier codes of conduct
Engaging with suppliers to improve practices and encourage corrective actions where issues are identified
Providing training and awareness for employees in higher‑risk roles (for example procurement, projects, HR and leadership)
Reviewing our risk assessment and controls periodically and updating them as laws, expectations, and our operations evolve

Where we identify credible modern slavery risks, we will seek to work with the relevant parties to address and remediate those risks, and we may terminate relationships where serious issues cannot be adequately resolved.

8. How to report modern slavery concerns

If you have a reasonably held suspicion of modern slavery practices connected to Veraspec, you should raise your concerns as soon as possible.

In the first instance, you can:

Contact our CEO at admin.aus@veraspec.com; or
Raise the concern with your manager, HR, or another senior leader, who will escalate it appropriately.

If there is immediate danger to life or safety, call the police or emergency services and do not put yourself or others at risk. Serious criminals can be involved in modern slavery and human trafficking.

Not all potential victims may want or be able to accept help, and raising concerns may put them at further risk. Unless there is an immediate threat, you should discuss your concerns internally first so that they can be managed safely and appropriately.

Veraspec will treat reports seriously, handle them as sensitively and confidentially as reasonably possible, and will not tolerate victimisation of anyone who raises a concern in good faith.

9. Roles and responsibilities

Our Board of Directors is ultimately responsible for overseeing this policy and Veraspec’s approach to modern slavery risk management.

Management is responsible for:

Implementing this policy in their business areas and supply chains
Ensuring that relevant risk assessments, due diligence, training, and contractual controls are in place
Reporting material issues or incidents to the Board

The Board will review this policy and any material reports on modern slavery risks or incidents at least annually, or more frequently if needed.

10. Review and availability of this policy

This policy may be updated, replaced, or withdrawn from time to time. The current version will be made available on our website at: http://www.veraspec.com/modern-slavery-policy

We encourage employees, suppliers, and other stakeholders to familiarise themselves with this policy and to contact us if they have questions about our approach to managing modern slavery risks.