Modern Slavery Statement

POLICY TYPE: People & Culture LAST UPDATED: July 2026

Introduction 

Limelight People are committed to operating our business lawfully and ethically and in only working with suppliers that are aligned to our values. We expect our suppliers to operate in  accordance with all applicable modern slavery laws including those prohibiting human  slavery and slavery like practices, human trafficking and child labour. We value and observe  all laws regarding corporate social responsibility, environmental and workplace safety  protection and staff inclusion and diversity. We have a whistle-blower policy and an external  hotline for staff and suppliers to use.  

We continue to set clear expectations that Limelight People employees and suppliers should  be alert to possible involvement in modern slavery and should work to prevent and address  it. We know that adopting high standards is not enough. Knowledge sharing, such as  targeted training programmes for employees, and action, including mitigation measures  where we see a risk of involvement, are vital to ensure our work stays relevant and effective.  

We have in place a number of relevant policies, procedures and standards to assist us in  protecting the human rights of staff and contingent workers, including in relation to human  trafficking and slavery.  

Particular steps we will undertake, include: 

  • Developing training for staff in modern slavery requirements  
  • Reviewing supplier contracts to ensure they contain terms that are consistent with the  Act  
  • Taking steps to address any potential modern slavery risks identified and setting up a  program to measure effectiveness through performance monitoring  
  • We seek to make positive and sustainable economic, social and environmental  contributions wherever we operate  
  • Maintain a safe and inclusive working environment where we treat each other with  respect  
  • Communicate responsibly and use technology appropriately
  • We’re all individually accountable for complying with the Code, and we call things out  which don’t seem right  
  • We act with honesty and integrity and don’t make or receive improper payments,  benefits or gains  

Limelight People takes breaches of its Code and Limelight People policies seriously,  investigates suspected failures to comply with the Code or Limelight People policies that it  becomes aware of, and takes a timely and proportionate approach to implementing  disciplinary or remedial action.  

Limelight People is committed to maintaining a safe workplace that values equal opportunity,  is free from discrimination, harassment and victimisation. Limelight People operates in a  highly regulated environment and has robust policies and procedures concerning  employment screening (including work eligibility checks), employment conditions and  appropriate workplace behaviour. All staff are expected to abide by the spirit, as well as the  strict requirements, of those policies and procedures outlined in the Limelight People Code  of Conduct.  

Labour and Human Rights:

We support the United Nations’ Universal Declaration of Human Rights. We work with  suppliers who uphold fundamental human rights including:  

  • Ensuring all work is freely chosen; without the use of forced or compulsory labour  • Ensuring all workers are of local legal age; and preventing the use of illegal child  labour  
  • Ensuring fair remuneration and work conditions for all workers  
  • Promoting humane treatment and preventing harassment and unfair discrimination  • Respecting workers’ rights to lawfully and peacefully form or join trade unions of their  choosing and to bargain collectively  
  • Respecting the privacy of employees and customers and complying with all laws in  the collection, use and protection of personal information 

Information and Reporting 

We build trust by communicating openly and honestly. We work with suppliers who provide information that is timely, accurate and relevant including:  

Maintaining accurate financial and business records, including invoicing, in accordance with all applicable legal and regulatory requirements and accepted accounting practices.  

Reporting on economic, social and environmental performance to meet regulatory and  contractual requirements. Ensuring the intellectual property rights of other parties (patents, trademarks, copyright, and confidential information) are respected.  

In an Emergency, Call 000

For suspected concerns: AFP 131 237 or online:  
https://forms.afp.gov.au/online_forms/human_trafficking_form 

Management Commitment 

Suppliers who work with Limelight People share our commitment to the principles raised in  this Supplier code of conduct by adopting and promoting the commitments in the code and  encouraging their subcontractors to do the same.  

Sincerley,

David Steven

David Steven  
Managing Director  
Limelight Consulting Group Pty LTD  

Ian Gingell

Ian Gingell  
Managing Director 
Limelight Consulting Group Pty LTD 

Dated 01 July 2026