Modern Slavery Statement
*Has been submitted to the regulator but not procesessed.
1. About this statement
This Modern Slavery Statement (Statement) describes the actions undertaken by the reporting entities, Versent Group Pty Ltd and Versent Pty Ltd (Versent), and their owned or controlled entities to identify, assess, and address the risks of modern slavery and human trafficking in our operations and supply chains.
This Statement is a joint modern slavery statement issued in accordance with the Modern Slavery Act 2018 (Cth) and covers the financial year ending 30 June 2026 (Reporting Period).
This Statement was prepared in consultation with Telstra, as the parent company of the reporting entities, and with relevant functions across Versent Group, including Legal, Governance, Risk & Compliance, People & Culture, Commercial, Finance and Procurement-related stakeholders.
Following advice from Telstra’s Office of the Company Secretary, communicated in April, Versent Group and its controlled entities have prepared their own statement because they meet the reporting criteria under the Modern Slavery Act 2018 (Cth). This approach is consistent with Telstra’s direction and provides clarity for the reporting entities amid uncertainty about Telstra’s completion timing.
2. Introduction
Versent Group is committed to operating ethically, responsibly and transparently. We recognise that modern slavery can occur in many forms, including forced labour, debt bondage, human trafficking, servitude, child labour and other forms of exploitation.
Our approach is guided by our values and our commitment to doing business with integrity. We seek to identify and manage modern slavery risks within our own operations and through our relationships with suppliers, partners and other third parties.
3. Our operations and supply chains
Our operations
Versent Group provides cloud, security, identity, digital modernisation, application development and managed cloud services. Our workforce is primarily professional and technology-based. The majority of our directly employed workforce is located in Australia, with a small group of six people based in the United States. Versent Group also engages an outsourced workforce in India and the Philippines, which we consider part of our direct operations for the purposes of this Statement.
Our supply chains
Versent Group procurement generally includes:
- Technology — software, cloud platform services, hardware, computers, network technology and related services.
- Facilities and property management — office-related services such as cleaning, maintenance, utilities, waste management, security, furniture, consumables and stationery.
- Marketing, travel, accommodation and events — advertising, events, travel, accommodation, entertainment and related services.
- Professional services — consulting, advisory, software development, legal, recruitment and other services.
- Labour hire and contingent workforce services — suppliers that support Versent Group contingent workforce requirements.
4. Risks of modern slavery practices in our operations and supply chains
Versent Group has assessed the risk of modern slavery within its direct business operations as low, given the professional nature of our directly employed and outsourced workforce, our employment practices, and our internal people and compliance controls.
We recognise that modern slavery risks may arise through our supply chains, suppliers, partners and third-party service providers. We generally assess our technology and professional services supplier base as lower risk where suppliers are established organisations with mature compliance, governance and modern slavery controls. We recognise elevated inherent risk in categories such as facilities and property management, travel, accommodation and event services, and labour hire, due to the potential involvement of lower-paid, migrant, temporary or vulnerable workers and subcontracting arrangements.
Higher-risk areas may include:
- recruitment and labour hire services in the Philippines;
- ICT hardware, office supplies and equipment;
- facilities and property management services, including cleaning, maintenance and security;
- travel, accommodation and event management services, including hospitality and logistics-related services;
- labour hire and contingent workforce providers, particularly where workers may be engaged through intermediaries or in higher-risk jurisdictions;
- smaller providers that may have less mature compliance frameworks or modern slavery controls; and
- suppliers or partners operating in jurisdictions, sectors or service categories associated with higher modern slavery risk.
During the Reporting Period, Versent Group didn’t identify any allegations of modern slavery, human trafficking or labour rights abuses involving our subsidiaries, suppliers or partners. If an allegation is made, Versent Group will take appropriate action, which may include investigation, remediation, escalation and, where appropriate, notification to relevant authorities.
5. Actions taken to assess and address modern slavery risks
Versent Group has continued to develop and strengthen processes to assess and address modern slavery risks in our operations and supply chains. Our key focus areas include:
- policies and governance;
- employee management;
- training and awareness;
- supplier due diligence;
- grievance and reporting mechanisms;
- contractual controls; and
- monitoring, remediation and continuous improvement.
Policies and governance
Versent Group maintains and adheres to policies and standards that support ethical conduct, fair treatment, safe reporting and compliance with applicable laws.
As subsidiaries of Telstra, Versent Group entities either adhere to Versent Group policies or, where required, applicable Telstra policies and standards. These policies reflect our ongoing commitment to ensuring our systems, relationships, and controls align with ethical modern slavery practices.
| Policy / process | Requirements |
|---|---|
| Code of Conduct | Sets ethical and lawful conduct expectations and supports escalation of labour rights concerns. |
| Partner Code of Conduct | Sets supplier and partner expectations for lawful, ethical and responsible labour practices. |
| Human Rights Policy | Sets the commitment to respecting human rights and supports the identification, prevention and management of modern slavery and labour rights risks. |
| Whistleblower Policy | Provides a protected pathway to report misconduct, exploitation or labour rights concerns. |
| Grievance Policy | Allows workers to raise workplace concerns and seek resolution. |
| Equal Employment Opportunity and Anti-Discrimination Policy | Supports fair, lawful and non-discriminatory employment practices. |
| Anti-Harassment and Bullying Policy | Prohibits bullying, harassment, intimidation and victimisation. |
| Overtime and Leave policies | Supports lawful working hours, leave access, rest and fair treatment. |
| Employment, recruitment and onboarding processes | Supports lawful recruitment, clear employment terms, verification and appropriate remuneration. |
These policies provide a framework for identifying, escalating and responding to unethical, unlawful or inappropriate conduct, including concerns that may relate to modern slavery or labour rights.
During FY26, Versent Group also reviewed its operations to check compliance with relevant policies.
FY26 progress against public commitments
During the Reporting Period, Versent Group continued work to integrate modern slavery reporting and supplier due diligence activities into existing governance processes, including whistleblower and supplier onboarding frameworks.
Versent Group’s FY26 public commitments and progress against them included:
| FY26 commitment | Progress during the Reporting Period |
|---|---|
| Embed the modern slavery questionnaire into supplier onboarding and review processes. | Met through the supplier onboarding control and questionnaire process described in the Supplier due diligence and supply chain check section. |
| Conduct additional diligence for higher-risk supplier categories. | Met through the supply chain check covering identified higher-risk categories, including facilities and property management, travel, accommodation and event management, and labour hire suppliers. |
| Monitor labour hire suppliers and address issues identified through supplier responses or reporting channels. | Met through issuing the modern slavery questionnaire to labour hire suppliers and reviewing responses, including the Philippines contingent workforce supplier. |
| Further integrate modern slavery reporting into whistleblower and governance arrangements. | Progressed through the confidential reporting channel and integration with existing whistleblower and governance processes. |
| Communicate reporting channels to suppliers, supplier workers and third parties. | Met through the compliance@versent.com.au reporting channel, which is provided as part of supplier due diligence processes. |
| Review grievance, supplier due diligence and remediation metrics to assess effectiveness. | Progressed through tracking questionnaire use, following up incomplete questionnaires, reviewing responses and monitoring whether reports were received. |
Employee management
Versent Group uses reputable recruitment channels and maintains processes for recruitment, onboarding, employment conditions, remuneration and employee support. These controls help reduce the risk of modern slavery in our direct workforce.
Relevant controls include:
- employment onboarding and compliance activities;
- annual remuneration and employment contract review processes;
- monitoring hours worked through a timesheet system in line with applicable law;
- a remuneration framework that applies to, and governs, minimum labour hire wages;
- policies relating to leave, overtime and working conditions;
- employee wellbeing programs;
- mechanisms for employees to raise concerns; and
- oversight by People & Culture and people leaders.
Versent Group regularly assesses compliance with local employment laws in the jurisdictions in which it operates, including by engaging external advisers where appropriate for non-Australian jurisdictions.
Training and awareness
During the Reporting Period, 199 Versent Group employees completed the appropriate modern slavery training course under Telstra’s training framework. This represented a 100% completion rate among employees who were required to undertake the course during the Reporting Period; the requirement did not extend to the entire Versent Group workforce.
Versent Group also supported modern slavery awareness through its communication plan, including internal communications and engagement with relevant stakeholders involved in supplier onboarding, procurement, people, legal, finance and governance activities.
As part of its continuous improvement commitment for the next reporting period, Versent Group intends to develop a modern slavery training course on the designated training platform, roll it out across all employees and monitor completion rates.
Supplier due diligence and supply chain check
Versent Group has embedded a modern slavery questionnaire into the supplier onboarding process and has issued it to existing suppliers. New suppliers are required to complete the questionnaire before onboarding, and responses are reviewed before suppliers are approved and added to Versent Group systems. Suppliers cannot be paid until they are onboarded.
During the Reporting Period, Versent Group completed a supply chain check by issuing and reviewing modern slavery questionnaire responses for identified higher-risk supplier categories, including facilities and property management, travel, accommodation and event management services, and labour hire suppliers.
The responses received were reviewed and assessed. No modern slavery risks or adverse indicators were identified in the responses received to date, and no escalation or remediation actions were required.
Labour hire suppliers
Versent Group issued its modern slavery questionnaire to labour hire suppliers and embedded this requirement into the relevant process and policy. Versent Group also issued a modern slavery questionnaire to the supplier of its contingent workforce in the Philippines, which was identified as higher risk, and completed a review of the submitted information.
Versent Group will continue to work with labour hire suppliers to remediate any issues identified through questionnaire responses, ongoing monitoring or other reporting channels. No modern slavery risks or adverse indicators were identified through responses received to date, and the review of the Philippines contingent workforce supplier indicated appropriate policies and processes were in place to mitigate labour rights risks.
Grievance and reporting mechanisms
Versent Group has established a dedicated reporting channel, compliance@versent.com.au, as a confidential grievance mechanism for workers, suppliers and other third parties to raise labour rights, modern slavery or other ethical concerns.
The mailbox was implemented in collaboration with People & Culture, communicated to the company through a company announcement, and is provided to suppliers and third parties as part of Versent Group modern slavery and supplier due diligence processes.
The mechanism has been integrated with Versent Group existing whistleblower and governance arrangements.
During the Reporting Period to date, no reports or emails were received through this channel.
Contractual and partner controls
Versent Group expects suppliers and partners to comply with applicable laws, human rights obligations and labour standards. Versent Group Partner Code of Conduct outlines expectations for business partners and reinforces Versent Group position that partners must act with honesty, integrity and compliance.
Versent Group also continues to include modern slavery and compliance-related expectations in supplier and partner engagement processes, including onboarding, questionnaires and contract-related controls where applicable.
6. Assessing the effectiveness of our actions
Versent Group is committed to a continuous improvement approach to assessing and improving the effectiveness of actions taken to reduce modern slavery risks.
During the Reporting Period, Versent Group assessed effectiveness by reviewing whether the FY26 commitments described above were implemented, whether supplier due diligence processes operated as intended, and whether any issues were identified through questionnaires, reporting channels or stakeholder engagement.
| Effectiveness measure | FY26 outcome |
|---|---|
| Supplier onboarding control | Modern slavery questionnaire embedded into onboarding before supplier approval and payment. |
| Higher-risk supplier review | Supply chain check completed for identified higher-risk supplier categories. |
| Questionnaire response review | Responses reviewed; no modern slavery risks or adverse indicators identified to date. |
| Labour hire monitoring | Labour hire suppliers reviewed, including the Philippines contingent workforce supplier. |
| Reporting channels | Confidential reporting channel established and monitored; no reports received to date. |
| Governance and stakeholder engagement | Internal engagement continued across Legal, People & Culture, Commercial, Finance and related functions. |
| Remediation | No escalation or remediation actions required during the Reporting Period to date. |
Based on these measures, Versent Group considers that its FY26 actions strengthened its modern slavery control environment. Versent Group will continue to monitor effectiveness and improve its processes as required.
7. Consultation with Telstra, reporting entities and owned or controlled entities
This Statement was developed through consultation with Telstra, as Versent Group’s parent entity, and with relevant Versent Group departments and stakeholders across the fully integrated Versent Group business. Versent Group Pty Ltd, Versent Pty Ltd and their owned or controlled entities operate under common governance, policies, systems and functional leadership, with shared oversight of operations, supply chains, risk management, people practices, supplier due diligence and reporting mechanisms.
The consultation process included engagement with Telstra and with the functions responsible for governance, legal, people, commercial, finance and supplier-related activities across the integrated Versent Group business. These stakeholders cooperated to provide information about Versent Group’s structure, operations, supply chains, policies, due diligence processes, grievance mechanisms and actions taken during the Reporting Period.
8. Recent developments and looking forward
Versent Group will continue to assess and improve its approach to modern slavery risk management. During the next reporting period, Versent Group intends to take the following specific and measurable actions:
- develop and approve a Versent Group modern slavery training module for relevant employees involved in procurement, supplier management, people, legal, finance and governance activities;
- assign the modern slavery training module to relevant employees and monitor completion rates;
- maintain the modern slavery questionnaire as a mandatory step in supplier onboarding before supplier approval and payment;
- review modern slavery questionnaire responses for all new suppliers onboarded during the reporting period;
- identify higher-risk supplier categories at least annually and complete targeted due diligence for selected suppliers in those categories;
- monitor the compliance@versent.com.au reporting channel and record whether any modern slavery, labour rights or related ethical concerns are received;
- review grievance, supplier due diligence and remediation metrics at least annually to assess whether existing controls remain effective;
- report progress against these commitments in the next modern slavery statement.
Versent Group remains committed to identifying, assessing and addressing modern slavery risks in its operations and supply chains, and to improving the effectiveness of its actions over time.