This statement is made pursuant to Section 13 of the Modern Slavery Act 2018 (Cth). Although The Trustee for Phil Labor Unit Trust (Phil Labor) does not currently meet the consolidated revenue threshold of $100 million for mandatory reporting, we elect to submit this voluntary statement to demonstrate our binding commitment to ethical labour practices and supply chain transparency.

1. Identity of the Reporting Entity
This statement covers the activities of The Trustee for Phil Labor Unit Trust (ABN: 67 626 399 370), trading as Phil Labor.

2. Structure, Operations, and Supply Chain
Phil Labor is an Australian-registered professional services provider operating a “Managed Services” model.

• Operations: Our management headquarters are in Victoria, Australia. Our operational teams are located in the Philippines.
• Employment Structure (The “EOR” Model): To ensure strict compliance with local labour laws, our staff are legally employed through a Philippines-registered third-party “Employer of Record” (EOR). This ensures all staff receive full government-mandated benefits under Philippine Law, including:
  • SSS (Social Security System)
  • PhilHealth (National Health Insurance)
  • Pag-IBIG (Home Development Mutual Fund)
  • 13th Month Pay (Mandatory statutory bonus)
• Supply Chain: Our primary supply chain consists of ICT infrastructure (hardware/software), commercial real estate (Clark Freeport Zone), and professional services.

3. Risks of Modern Slavery Practices
We acknowledge that the outsourcing sector in Southeast Asia carries risks of “modern slavery” as defined in Divisions 270 and 271 of the Criminal Code Act 1995 (Cth) (View Legislation). Specifically, we monitor for:

• Debt Bondage: The practice of forcing employees to purchase their own equipment or uniforms via loans, effectively bonding them to the employer until the debt is paid.
• Deceptive Recruiting: Misrepresentation of employment terms or withholding wages/identity documents to coerce continued service (Division 270.7).

4. Actions Taken to Assess and Address Risks
Phil Labor actively shields its workforce from these practices through the following controls:

• Zero-Debt Equipment Policy: We supply all necessary IT equipment (Laptops, 2000VA UPS power units, peripherals) at company expense. We strictly reject “Bring Your Own Device” (BYOD) arrangements that require staff to take out loans for work tools. Staff are never in debt to Phil Labor or any of our partners related to their legal employment within The Philippines.
• Freedom of Movement & Association: We do not withhold identity documents, nor do we enforce “administrative penalties” (e.g., charging staff for lost ID cards) that serve only to withhold pay. Staff are free to resign with standard notice periods without financial penalty.
• Workplace Health & Safety (WFH Support): Recognizing the infrastructure challenges in the Philippines, we provide home-office support (UPS/Battery backups) to ensure staff safety and continuity during typhoons or power outages. This allows staff to work from the safety of their homes rather than commuting during hazardous weather conditions.

5. Voluntary Alignment with Australian Standards
While our staff are legally employed under Philippine jurisdiction and subject to the Labor Code of the Philippines, Phil Labor voluntarily adopts Australian cultural standards for staff treatment:

• Leave Entitlements: We provide paid leave allowances (Vacation, Sick, and Parental) structured to align with Australian National Employment Standards (NES) mentalities, ensuring staff have adequate rest and recovery time beyond the local statutory minimums.
  • Reference: Fair Work Act 2009 – Sect 70 (Parental Leave)
  • Reference: Fair Work Act 2009 – Sect 96 (Personal/Carer’s Leave)
• Private Healthcare: In addition to mandatory PhilHealth contributions, we fund private healthcare coverage to ensure staff access to quality medical services.

6. Assessing Effectiveness & Consultation

• Consultation with Controlled Entities (Criterion 6): This statement was prepared in direct consultation with our Philippines-based Employer of Record partners. We regularly audit employment contracts and payroll data provided by these partners to ensure the working conditions described in this statement are being upheld in practice.
• Monitoring: We assess effectiveness by monitoring staff retention rates and voluntary “make-up” hours. We observe that staff frequently volunteer to recover hours lost due to natural disasters, indicating a relationship based on mutual respect rather than coercion.
• Remediation: In the event that modern slavery practices are identified within our supply chain, Phil Labor commits to working with the relevant EOR and local authorities to ensure the victim is protected and the practice is immediately ceased.

Approved by the Board of The Trustee for Phil Labor Unit Trust, January 2nd, 2026