Introduction

Sandstone Technology Pty Ltd (“Sandstone”) is committed to treating all workers with respect and dignity, ensuring safe working conditions, and conducting environmentally responsible ethical operations. As a part of our overall commitment to supporting human rights around the world, we stand against all forms of modern slavery, and we work to ensure it will not find a foothold in our supply chains and business operations. Although Sandstone does not legally fall within the reporting threshold required to comply with the Australia Modern Slavery Act 2018 and United Kingdom Modern Slavery Act 2015, this Statement follows the prescribed framework under these legislation.

Throughout this Statement, we refer to “modern slavery” as a term to describe situation where coercion, threats or deception are used to deprive individuals of their freedom to work, which includes slavery, servitude, forced or compulsory labor, and human trafficking.

Sandstone does not tolerate slavery, human trafficking, forced labour or child exploitation of any kind and we have a suite of policies, procedures and practices in place, which assist us in managing human rights, promoting diversity and ensuring compliance with legislation. We believe that modern slavery has no place in our operations or supply chains and that business and governments need to work together to make progress on this complex issue.

1.Sandstone’s Business and Structure

Sandstone is a financial technology provider of products and software for banks, financial institutions, credit unions within regions of Australia, New Zealand and the United Kingdom. We work with more than 150 suppliers worldwide that support our business and operations. These include software, hardware, custom support as well as our extended workforce. We seek to engage suppliers and contractors who have similar ethical approach in doing business and have taken steps to implement controls and system in managing the risk of modern slavery within its supply chain. We work closely in partnership with our suppliers with the mutual benefit of mitigating risk of modern slavery occurring in the supply chains.

1.1 Policies Addressing Ethical Conduct and Prevention of Modern Slavery

The behaviour and conduct of Sandstone’s staffs and suppliers in performing their duties and functions must be informed by the Sandstone’s commitment to address modern slavery.

Our Code of Conduct and Equal Employment Opportunity Policy outlines our commitment for a fair, safe and ethical work environment free from discrimination, harassment, bullying, workplace violence, vilification, child and forced labour within our business and our supply chain. All reports of breaches or concerns relating to the Code of Conduct will be treated seriously and anonymously, including but not limited to disciplinary actions under our Discipline and Termination Policy.

Sandstone has also adopted various policies relating to recruitment and employee management to ensures that:

1. all our legal obligations are covered within the recruitment and on-boarding process;
2. individuals are free to apply for work, free to turn down an offer of work and free to leave work at any time;
3. employees are free to apply for change in work arrangement described under our Employee Transition Process;
4. every employee is provided with a copy of the terms and conditions of their engagement including rates of pay, hours worked and entitlements.

Our Whistleblowing Policy outlines the mechanisms available to our employees for the reporting of behaviour or practices that are inconsistent with this Statement. The policy provides multiple recipient contacts and reporting options to employees by email, phone or post. These reporting options are promoted through our internal policies, communications, and trainings. All reports will be treated anonymously. If a reported breach of this Statement is verified, Sandstone’s corrective response may involve working collaboratively with the supplier to address the issue or, if the issue is unresolved, terminating the supplier.

2.Our Approach to Managing Modern Slavery Risk

Sandstone has established and developed our Modern Slavery framework which includes the following:

1. Modern Slavery Statement
2. Modern Slavery Training
3. Third Party Due Diligence Questionnaire

We have adopted a risk-based approach to managing any potential modern slavery vulnerabilities within our business and our supply chain. Whilst we consider the risk of modern slavery within our direct business operations to be low, we recognise that through our supply chain we can be exposed to the risk of modern slavery.

We have used available internal resources, external published sources and feedback from our direct clients, such as banks, financial institutions, credit unions, to inform our risk assessment approach.

2.1 Training

Sandstone provides its employees with annual online training course and information in identifying third parties that engage in modern slavery or other illegal practices. This helps employees to identify modern slavery red flags, shares best practices against risk of modern slavery, and instructs workers to report modern slavery concerns. As of March 2024, it is mandatory for all employees to complete the online training course.

2.2 Sandstone’s Supply Chain and Key Indicators of Risk

Sandstone’s worldwide supplier base can be grouped into four main categories:

1. Internal product components, information technology, software, hardware and security;
2. External software, applications and services attach to Sandstone’s product;
3. Professional services, including provision of contractors; and
4. Real estate, property services and other office suppliers.

Suppliers are the main service or license providers to Sandstone’s business and products. However, a number of suppliers are classified as business partners via engagements such as reseller, distributor promoter, collaboration, etc. Sandstone acknowledges the risk in engaging external suppliers appointed or requested by our customers that have not been progressed via Sandstone’s procurement process, and have nevertheless applied the same level of due diligence on those suppliers.

In identifying the key indicators of modern slavery risks, Sandstone considered multiple elements such as recognised modern slavery risk indices, country and industry risk analysis. Within our supply chain, the following have been identified as the key indicators of modern slavery risks:

Where multiple high risk indicators co-exist, there is a higher likelihood of modern slavery and additional controls are required to ensure these risks do not become reality.

When measured by value, the majority of supplier spend is on large, established businesses based in Australia, the United States of America and the United Kingdom, which are considered to have medium-low level of modern slavery risk comparing to smaller businesses in most other countries. However, Sandstone acknowledges that the procurement of professional services and contractors based offshore carry a relatively higher risk of modern slavery, unhealthy working environment and worker exploitation.

2.3 Supplier Risk Assessment and Due Diligence

To identify, prevent and mitigate actual and potential adverse modern slavery risks and impacts within our supply chains, Sandstone continually assesses modern slavery risk through Third Party Due Diligence Questionnaire.

In 2021 we established our supplier risk assessments to include components specific to modern slavery. Our assessment includes a Modern Slavery Due Diligence Questionnaire and desktop research (where available) to gain an understanding of each supplier’s approach, controls, identification procedures and mitigations in addressing modern slavery. We also consider the industry, work type, geography, Global Slavery Index, and supplier reputation, among other factors.

Since August 2021, it is mandatory for all new and renewing suppliers to undergo this Supplier Risk Assessment. Although we expect our suppliers to identify and manage their own Modern Slavery risks in-accordance with Modern Slavery legislation, we intend on conducting reviews of our supply chain on a regular basis. If we discover red flags, we conduct extensive and documented follow-ups to address these issues. In certain cases, we may decide to no longer pursue a relationship or to terminate our current relationship with a supplier.

We investigate any issues identified during the assessment and we expect the supplier to provide a corrective action plan for any non-conformance issues, which that outlines the root cause of the finding, how and when that supplier will resolve the issue, and the steps taken to prevent recurrence. We determine whether the plan is acceptable based on the severity of the non-conformance in addition to the effort and time required to resolve the issue. We monitor and verify all corrective actions are completed in the agreed upon time frame.

Like many businesses, Sandstone acknowledges that there is limited insight into our supply chains beyond our direct suppliers. Latest update to our supplier assessment questionnaire specifically targets this area.

3. Looking Forward

Modern slavery remains a complex challenge. Our efforts to combat these practices are ongoing, evolving, and continually improving. Over the next 18 to 24 months, Sandstone is focused on reducing any potential Modern Slavery risks and some of our key initiatives include:

1. maturing our policies and procedures to ensure these have a robust and consistent focus on human rights and Modern Slavery;
2. gap analysis and continuous improvement of our existing controls;
3. improving and expanding our engagement with and understanding of our Suppliers and their supply chains with regards to human rights and modern slavery;
4. include specific modern slavery provisions in contractual documentation with suppliers and partners, as appropriate for the engagement; and
5. enhancing our training and compliance framework for staffs to include an emphasis on forced labour, deceptive, coercive or intimidating practices, designed to build awareness across our business.

This statement was reviewed by relevant internal teams and approved by the Advisory Committee of Sandstone Technology Pty Ltd, the parent and holding company for Sandstone Technology (Europe) Limited and Sandstone Technology Phils., Inc.