Anti-Slavery Policy


PhoenixDX, trading as ‘Phoenix Advisory & Technology Services Pty Ltd’ (the Company) is committed to limiting the risk of modern slavery occurring within its own business, in its supply chains or through any other business relationship.

Modern Slavery can take many forms but fundamentally is a range of exploitive practices including human trafficking, slavery, forced labour and child labour all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

As part of its commitment, the Company will comply with all applicable Australian and International slavery legislation including the Modern Slavery Act 2018 (Clth) and the Modern Slavery Act 2018 (NSW).

This policy will be used to underpin any statement on modern slavery that is required to be made under that applicable legislation.



This policy applies to all persons working for and on behalf of the Company in any capacity, including employees, directors, officers, agency workers, contractors, consultants and any other third party representatives.

The Company expects all who have, or seek to have, a business relationship with the Company to familiarise themselves with this policy and to act in a way that is consistent with its values.



The Company has a zero-tolerance approach to all forms of modern slavery within its business and within its operations and is committed to acting ethically and with integrity in all of its business dealings and relationships and implementing and enforcing effective systems and controls to ensure modern slavery is not taking place in its own business or any of its development centres.

As part of our approach, we have in place or will put in place the following elements of a Company programme designed to prevent and detect modern slavery including:

  • A policy which articulates the Company’s commitment to preventing modern slavery
    within its operations and supply chains, being this policy.
  • Communication of this policy and all relevant elements of the programme to all employees throughout the Company and our business partners and development centres.
  • The assessment of modern slavery and human trafficking risk within the Company and operations and the development of effective, efficient and transparent controls to reduce exposure to those risks.
  • The adoption of anti-slavery wording in contracts.
  • The adoption of appropriate due diligence on business partners, agents, contractors, consultants, sub-contractors and suppliers, coupled with the requirement that they implement procedures which incorporate the principles under the applicable modern slavery legislation.
  • Training of all relevant individuals throughout the Company so that compliance with this policy is the duty of all relevant employees at all levels and individuals can recognise modern slavery practices and take steps to avoid the same.


You are required to be proactive and promptly report any suspected violation of this policy. Complaints will be kept confidential and will be dealt with appropriately.


Communication and Awareness

Training on this policy and on the risk our business faces from modern slavery in its supply chains will be provided annually (and as otherwise necessary).


Breaches of this Policy

Any employee who breaches this policy by engaging in or conspiring to engage in any modern slavery conduct will face disciplinary action.

The Company may terminate its relationship with other individuals and organisations working on its behalf or engaged by it if they breach this policy.