Modern Slavery Policy

Elite Maintenance Services Group Pty Ltd

This Modern Slavery Policy outlines Elite Maintenance Services Group Pty Ltd's (Elite) commitment to preventing modern slavery, forced labour, human trafficking, and exploitation within our business operations and supply chains.

1. Purpose

Elite is committed to conducting business ethically, transparently, and in accordance with the Modern Slavery Act 2018 (Cth). The purpose of this policy is to ensure we identify, prevent, and address risks of modern slavery in all forms across our operations, subcontractors, and suppliers.

2. Scope

This policy applies to all employees, contractors, subcontractors, franchisees, suppliers, and business partners engaged by Elite Maintenance Services Group Pty Ltd across all divisions, including Elite Cleaning, Elite Restoration, and Elite Carpet Cleaning.

3. Definition of modern slavery

Modern slavery refers to situations where coercion, threats, or deception are used to exploit individuals and deprive them of their freedom. It includes forced labour, human trafficking, debt bondage, servitude, forced marriage, and child labour.

4. Our commitment

Elite Maintenance Services Group is committed to:

• Operating with integrity and zero tolerance toward all forms of modern slavery.
• Conducting due diligence on suppliers and subcontractors to assess risks of exploitation.
• Maintaining transparent business practices and traceable supply chains.
• Training staff to recognise and report signs of modern slavery.
• Working with suppliers and regulators to improve labour conditions where risks are identified.

5. Risk management and due diligence

Elite will undertake ongoing risk assessments of our operations and supply chains to identify potential areas of vulnerability. These assessments will include:

• Supplier vetting before engagement.
• Requiring all suppliers and subcontractors to adhere to our Code of Conduct.
• Auditing high-risk suppliers or labour-hire providers periodically.
• Investigating and addressing any reported concerns or suspected breaches.

6. Reporting and remediation

Elite encourages all employees, subcontractors, and suppliers to report any concerns regarding modern slavery practices confidentially to management or via designated reporting channels. We will investigate all reports and, where necessary, collaborate with authorities to take corrective action and protect affected individuals.

7. Training and awareness

Elite will provide training to employees and managers to raise awareness of modern slavery risks and ensure they understand their responsibility in identifying and preventing such practices within their areas of influence.

8. Continuous improvement

Elite is committed to continually improving its systems and processes to reduce modern slavery risks. Annual reviews of this policy and associated procedures will be conducted to ensure effectiveness and compliance with legislative obligations.

9. Governance and accountability

Responsibility for implementing this policy lies with the Managing Director and senior management team. Compliance with this policy forms part of Elite's ethical governance framework and aligns with our corporate values of integrity, respect, and accountability.

10. Policy review

This policy will be reviewed annually, or earlier if there are significant changes in legislation or our operational context. Updates will be communicated to all relevant parties.

Guosheng Wang
Director & CEO
1 February 2025