18 December 2025

Introduction

Sandstone Technology Pty Ltd (“Sandstone”) is committed to treating all workers with respect and dignity, ensuring safe working conditions, and conducting 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 framework prescribed by these laws.

Throughout this Statement, we refer to “modern slavery” as a term to describe situations where coercion, threats or deception are used to deprive individuals of their freedom to work, examples of which include slavery, servitude, forced or compulsory labour, 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. Our business practices, policies and risk-based approach to mitigating the modern slavery risks in our business and supply chains are shaped and guided by the United Nations Guiding Principles on Business and Human Rights and the pillars of responsibility for businesses to respect all human rights and the OECD guidance on responsible business guidance.

 

1. Sandstone’s Business and Structure

Sandstone is a financial technology provider of products and software for over 20 banks, financial institutions and credit unions within regions of Australia, New Zealand and the United Kingdom. Sandstone operates out of three main locations with offices in Sydney, Australia, Leeds, United Kingdom and Manilla, Philippines, across all of which we employ over 300 people. Presently, we work with over 50 key vendors as well as up to 150 ongoing and ad-hoc 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.

As a provider of on-premises software and software-as-a-service solutions, modern slavery is not a high risk in Sandstone’s business or operations. Our operations are underpinned by a streamlined supply chain that minimises subcontracting and relations with industries typically associated with higher risks of modern slavery. This structure significantly minimises our exposure to modern slavery risk factors.

1.1 Policies Addressing Ethical Conduct and Prevention of Modern Slavery

The behaviour and conduct of Sandstone’s staff and suppliers in performing their duties and functions is informed by Sandstone’s commitment to address modern slavery.

Our Code of Conduct, Equal Employment Opportunity Policy and Corporate Social Responsibility Policy outline our commitment to 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, the consequences of such include, but are not limited to, disciplinary actions under our Discipline and Termination Policy.

Sandstone has also adopted jurisdiction-dependant policies for recruitment and employee management to ensure that:

1. all our legal obligations are considered and complied with during 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. Once a reported breach of this Statement is verified, Sandstone’s corrective response may involve working collaboratively with the relevant supplier to address the issue or, if the issue is unresolved, terminating the supplier.

2. Our Approach to Managing Modern Slavery Risk

Sandstone, with input from the Legal, Risk & Compliance and Human Resources teams, 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 such as our legal register, external published sources concerning the modern slavery laws in the jurisdictions which we operate and feedback from our direct clients, such as banks, financial institutions and credit unions, to inform and continuously improve upon our risk assessment approach.

2.1 Training

Sandstone’s Human Resources department provides all employees with an annual, online training course delivered through an external, digital training provider 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 business practices for minimising and mitigating the risk of modern slavery, exposes the employees to real world examples of complex modern slavery cases and instructs workers on the appropriate channels to report modern slavery concerns. As of March 2024, it is mandatory for all employees to complete the online training course, and such completion is monitored by the Human Resources department.

2.2 Sandstone’s Supply Chain and Key Indicators of Risk

Sandstone directly engages with global suppliers predominately within Australia, the United Kingdom, the Philippines and the United States of America as required to reflect business and operational needs. 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 that attach to Sandstone’s product;
3. Professional services, including provision of contractors; and
4. Real estate, property services and other office suppliers.

Most of Sandstone’s service or license providers are categorised as suppliers.. However, a small portion of suppliers are classified as business partners via engagements such as reselling, distributor promotion or collaboration. 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 when engaging those suppliers.

In identifying the key indicators of modern slavery risks, Sandstone considered multiple elements such as the Global Slavery Index, country of operation and industry risk analysis. When considering onboarding a supplier into our supply chain, the following have been identified as key indicators of a modern slavery risk:

1. Occurrences of modern slavery or human rights abuses within their business or supply chains.
2. Limited transparency about supply chains.
3. Non-existent or poor governance and due-diligence frameworks.
4. The organisation or their major suppliers operating out of geographical regions that are at a high risk of modern slavery as identified by the Global Slavery Index.
5. Extensive outsourcing and subcontracting practices.

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 that operate in geographical regions with higher risks of modern slavery, which arise limited legal or regulatory protections. 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, as such our engagement with such suppliers and contractors is limited and subject to due diligence practices.

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’s Risk & Compliance team continually assesses modern slavery risk through the Third-Party Due Diligence Questionnaire.

In 2021, we established our supplier risk assessment process to include components specific to modern slavery. Our assessment includes the specified modern slavery questions in the Third-Party Due Diligence Questionnaire, desktop research (where available) and reaching out directly to the potential supplier (where required) to gain a deeper understanding of each supplier’s approach, controls, identification procedures and mitigation measures to address modern slavery in their operations and supply chains.

Since August 2021, it is mandatory for all new and renewing suppliers to undergo this supplier risk assessment process. Although we expect our suppliers to identify and manage their own modern slavery risks in-accordance with applicable modern slavery legislation, we conduct reviews of our supply chain and assessment processes on a regular basis. If we discover red flags, we conduct extensive and documented investigations to address the identified issues. In certain cases where we discover that a supplier’s activities are not aligned with our Code of Conduct and practices regarding modern slavery, we may decide to no longer pursue a relationship or to terminate our current relationship with the relevant supplier.

We investigate any risks that have been identified during the assessment and we expect the supplier to provide a corrective action plan for any non-conformance issues, which 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 that 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. In 2024, we updated our supplier assessment questionnaire to specifically target this area. The Third Party Due Diligence Questionnaire now includes questions relating to the supplier’s internal due diligence practices to identify any potential risks of modern slavery practices in their operations and whether there has been any suspected or actual occurrences of modern slavery or human rights violations within their supply chains.

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.
6. increasing our engagement with external stakeholders to enhance our due diligence in relation to the identified modern slavery risks in our direct and indirect suppliers.
7. revising and improving our Third Party Due Diligence Questionnaire to create a high level profile of our indirect suppliers and enhancing our practices for the cadence and scope of assessments.

Sandstone implements Key Performance Indicators (KPIs) relating to the annual completion of the modern slavery training modules by all employees. Sandstone further implements additional KPIs for the Risk and Compliance team to reassess the modern slavery risks of our key vendors on an annual basis. To ensure continuous improvement, we are committed to conducting annual reviews of our policies and procedures to assess their effectiveness in preventing modern slavery across our business and publish annual updates to this modern slavery statement to reflect any changes.

At this stage, since implementing and updating our process for identifying assessing modern slavery risks in our suppliers, Sandstone has not identified any high risks associated with modern slavery or human rights violations in supply chains.

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.