Modern Slavery Statement

1.1 Purpose

Tool-O is committed to conducting business ethically, responsibly and with respect for human rights.

This Modern Slavery Statement outlines Tool-O's commitment to preventing modern slavery, forced labour, human trafficking and other forms of exploitation within its operations and supply relationships.

1.2 Commitment

Tool-O does not tolerate:

• modern slavery;

• forced labour;

• bonded labour;

• child labour;

• human trafficking;

• servitude;

• exploitation;

• any conduct that infringes fundamental human rights.

1.3 Scope

This Statement applies to:

• Tool-O;

• Platform operations;

• employees;

• contractors;

• consultants;

• suppliers;

• service providers;

• business partners where appropriate.

1.4 Guiding Principles

Tool-O seeks to conduct its business in accordance with principles of:

• integrity;

• transparency;

• accountability;

• ethical sourcing;

• respect for human rights;

• lawful business practices.

1.5 Relationship with Other Policies

This Statement should be read together with the:

• Terms of Use;

• Privacy Policy;

• Acceptable Use Policy;

• Community Guidelines;

• all other Platform policies.

1.6 Updates

Tool-O may update this Statement from time to time.

The latest version published on the Platform replaces all previous versions.

2.1 Commitment to Ethical Business

Tool-O seeks to conduct its business in a manner that promotes ethical business practices and respect for internationally recognised human rights.

2.2 Risk Awareness

Tool-O recognises that modern slavery risks may arise within:

• supply chains;

• outsourced services;

• technology providers;

• contractors;

• labour hire arrangements;

• business partnerships.

2.3 Due Diligence

Where appropriate, Tool-O may undertake reasonable due diligence before engaging suppliers or service providers, taking into account:

• the nature of the services;

• geographic risk;

• industry risk;

• publicly available information;

• contractual obligations;

• other relevant factors.

2.4 Supplier Expectations

Tool-O expects suppliers and service providers to:

• comply with applicable laws;

• treat workers fairly;

• prohibit forced labour;

• prohibit child labour;

• provide lawful working conditions;

• respect human rights.

2.5 Reporting Concerns

Employees, contractors, suppliers and other stakeholders are encouraged to report any genuine concerns regarding suspected modern slavery or unethical labour practices.

Reports should be made honestly and in good faith.

2.6 Investigation

Tool-O may investigate reports of suspected modern slavery using information reasonably available to it.

Where appropriate, Tool-O may seek further information from relevant parties.

2.7 Corrective Action

Where Tool-O reasonably identifies unacceptable practices, it may take appropriate action, including:

• engaging with the relevant party;

• requesting corrective action;

• reviewing contractual arrangements;

• suspending engagement;

• terminating commercial relationships where appropriate.

2.8 Training and Awareness

As Tool-O grows, it may implement training and awareness initiatives designed to help relevant personnel identify and respond to modern slavery risks.

2.9 Continuous Improvement

Tool-O is committed to reviewing and improving its processes for identifying, assessing and managing modern slavery risks as the business develops.

2.10 Compliance

Tool-O seeks to comply with applicable modern slavery legislation and regulatory requirements relevant to its operations.

3.1 Responsible Business Practices

Tool-O seeks to integrate ethical business practices into its operations and decision-making processes as the Platform grows.

3.2 Supplier Engagement

Where appropriate, Tool-O may communicate its expectations regarding:

• lawful employment practices;

• ethical sourcing;

• worker welfare;

• compliance with applicable laws;

• respect for human rights.

3.3 Contractual Expectations

Where appropriate, agreements with suppliers or service providers may include obligations relating to:

• compliance with applicable labour laws;

• ethical business conduct;

• human rights;

• anti-exploitation practices;

• cooperation with reasonable compliance requests.

3.4 Monitoring

Tool-O may periodically review its suppliers and service providers having regard to:

• the nature of the services provided;

• identified risks;

• publicly available information;

• previous compliance history;

• other relevant circumstances.

3.5 Reporting Mechanisms

Tool-O encourages the reporting of suspected modern slavery concerns through appropriate reporting channels.

Reports should include sufficient information to enable reasonable assessment where possible.

3.6 Confidentiality

Reports of suspected modern slavery will, where reasonably practicable, be handled confidentially, subject to legal obligations and the need to conduct a fair investigation.

3.7 Response to Concerns

Where credible concerns are identified, Tool-O may:

• seek additional information;

• engage with the relevant organisation;

• request corrective measures;

• monitor remediation;

• suspend engagements where appropriate;

• terminate business relationships where appropriate.

3.8 Continuous Review

Tool-O intends to review its policies, procedures and risk management practices periodically to strengthen its approach to identifying and addressing modern slavery risks.

3.9 Cooperation

Tool-O expects employees, contractors, suppliers and business partners to cooperate with reasonable requests relating to modern slavery compliance and investigations.

3.10 Commitment to Improvement

Tool-O recognises that effective modern slavery risk management is an ongoing process and is committed to continuously improving its governance, due diligence and ethical business practices.

4.1 Ongoing Review

Tool-O will periodically review this Statement to ensure it remains appropriate for the size, nature and development of the Platform.

4.2 Monitoring Effectiveness

Tool-O may assess the effectiveness of its modern slavery framework by considering factors including:

• identified risks;

• supplier engagement;

• internal reporting;

• corrective actions;

• legislative developments;

• operational changes.

4.3 Policy Updates

Tool-O may amend this Statement from time to time to reflect:

• changes in business operations;

• changes in applicable laws;

• improvements to governance;

• evolving industry practices;

• lessons learned through implementation.

4.4 Accountability

Management is responsible for promoting ethical business practices and supporting compliance with this Statement throughout Tool-O's operations.

4.5 Cooperation

Employees, contractors, suppliers and business partners are expected to cooperate with reasonable requests relating to compliance with this Statement.

4.6 No Waiver

Failure by Tool-O to enforce any aspect of this Statement at any time does not constitute a waiver of its rights.

4.7 Australian Modern Slavery Act

Where applicable, Tool-O intends to comply with the requirements of the Modern Slavery Act 2018 (Cth) and any other applicable legislation.

4.8 Relationship with Other Policies

This Statement should be read together with the:

• Terms of Use;

• Privacy Policy;

• Acceptable Use Policy;

• Community Guidelines;

• all other Platform policies.

Where there is any inconsistency, the Terms of Use prevail to the extent permitted by applicable law.

4.9 Questions

Questions regarding this Statement may be directed to Tool-O using the contact details published on the Platform.

4.10 Final Commitment

Tool-O is committed to operating a responsible marketplace that respects human rights, promotes ethical business practices and continually improves its approach to identifying, assessing and addressing modern slavery risks.

END OF MODERN SLAVERY STATEMENT