SpacetoCo Anti-Slavery Statement

We are committed to acting ethically and with integrity in all business dealings and relationships, and where possible, to ensure modern slavery is not taking place in our own business or supply chain. As part of our contracting processes, we will include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude. 

Our business also expects its service providers, suppliers and contractors to share our commitment to act lawfully and ethically and to work to ensure that modern slavery is not taking place within its organisation or within its supply chain. 

Definitions 

The term ‘modern slavery’ describes situations where coercion, threats or deception are used to exploit victims and undermine their freedom. Coercion, threats and deception can be explicit or implicit. The Modern Slavery Act 2018 (Cth) ‘Act’ defines modern slavery as including eight types of serious exploitation; trafficking in persons, slavery, servitude, forced labour, forced marriage, debt bondage, the worst forms of child labour and deceptive recruiting for labour or services.

The worst forms of child labour means extreme forms of child labour that involve the serious exploitation of children, including through enslavement or exposure to dangerous work. The worst forms of child labour does not mean all child work. Under Australian law, modern slavery is defined in the Act. In the event of any inconsistency, the definitions in the Act take precedence over this policy

Responsibilities

The Directors of SpacetoCo hold overall responsibility for ensuring that this policy aligns with SpacetoCo’s legal and ethical obligations and that all employees under their supervision comply with it. They are also responsible for approving SpacetoCo’s annual Modern Slavery Statement and ensuring it meets the disclosure requirements under applicable Modern Slavery legislation.

The Directors are accountable for the day-to-day implementation and oversight of this policy. This includes managing inquiries, monitoring internal controls to identify potential modern slavery risks within SpacetoCo’s operations, and reviewing the activities of suppliers, contractors, and business partners to detect and address any modern slavery risks within SpacetoCo’s supply chains. They must also oversee the effectiveness of these measures, ensure that appropriate employee training is developed and delivered, and prepare the annual Modern Slavery Statement in accordance with reporting obligations.

At every level, management is responsible for ensuring that their team members understand and comply with this policy and receive consistent and relevant training on modern slavery risks in supply chains—particularly in areas of SpacetoCo’s operations identified as higher risk.

Feedback, suggestions, or questions about this policy are welcomed and should be directed to the SpacetoCo Directors.