Modern Slavery Statement

1. Statement of Commitment

Red Owl Pty Ltd (ACN 676 456 321) ("RedOwl", "we", "our", or "us") is firmly committed to operating ethically, transparently, and with integrity across all facets of our business. We hold a zero-tolerance policy towards modern slavery, human trafficking, forced labour, debt bondage, child exploitation, and any form of human rights abuses within our direct operations and our global supply chains.

This Modern Slavery Statement sets out the actions taken by RedOwl to identify, assess, mitigate, and remedy potential modern slavery risks in our operations and supply chains in compliance with the Australian Modern Slavery Act 2018 (Cth).

2. Organisational Structure, Operations & Supply Chain

2.1 Operations: RedOwl is an Australian financial technology company headquartered in Sydney, Australia. We provide enterprise accounts payable leakage prevention, AI-driven fraud detection, and spend governance software solutions. Red Owl Pty Ltd operates as an Authorised Representative (AR No. 1313293) of Nium Pty Limited (AFSL No. 464627).

2.2 Supply Chain: Our supply chain primarily comprises professional services, cloud computing infrastructure (e.g., tier-1 cloud hosting and security providers), software licensing, legal and accounting advisory, office facilities, and telecommunications. Because our core business is software and technology services, our direct supply chains are characterised by skilled, professional labour with low inherent risk of forced labour.

3. Risk Assessment & Due Diligence

We undertake structured risk assessments across our operational footprint and vendor ecosystem:

• Vendor Onboarding Due Diligence: Prior to engaging any major supplier or technology vendor, RedOwl assesses the vendor's human rights policies, compliance track record, and employment standards.
• High-Risk Sector & Geography Screening: We evaluate suppliers against international risk indexes (such as the Global Slavery Index) to flag higher-risk jurisdictions or manufacturing sectors.
• Contractual Safeguards: Our standard supplier agreements require vendors to warrant compliance with applicable anti-slavery laws, uphold safe working conditions, and promptly report any suspected human rights breaches.

4. Key Policies & Governance Mechanisms

Our commitment to human rights is reinforced through a suite of internal policies and operational guidelines:

• Code of Conduct & Business Ethics: Mandates fair labour practices, mutual respect, non-discrimination, and lawful working conditions across our team.
• Whistleblower Protection Policy: Provides confidential and protected reporting channels for employees, contractors, and external partners to report suspected illegal, unethical, or exploitative conduct without fear of retaliation.
• Supplier Code of Conduct: Sets explicit expectations for our suppliers regarding fair wages, legal working hours, health and safety standards, and voluntary employment.
• Anti-Bribery & Corruption Policy: Complements our ethical governance to prevent corrupt practices that often underpin labour exploitation.

5. Training & Awareness

We provide training to employees—particularly those in procurement, finance, executive leadership, and vendor management—on recognising indicators of modern slavery, understanding supply chain risks, and following escalation procedures when red flags are detected.

6. Incident Reporting & Remediation

If modern slavery or severe labour exploitation is identified or suspected within our supply chain, RedOwl will take immediate action. This includes investigating the matter thoroughly, working with affected stakeholders to provide remediation where appropriate, requiring corrective action plans, or terminating relationships with non-compliant suppliers.

7. Continuous Improvement & Effectiveness Measurement

We review the effectiveness of our anti-slavery measures annually by assessing vendor compliance audit results, staff training completion rates, and feedback from internal and external stakeholders. We continuously refine our screening technologies and governance controls to stay ahead of emerging risks.

8. Contact & Whistleblower Inquiries

If you have any questions about this statement, suspect potential modern slavery within our supply chain, or wish to make a confidential inquiry, please contact our Compliance Officer: