Modern Slavery and Ethical Sourcing Policy

Agency Name: Contrarian Path

Policy Effective Date: 5th Jan 2026

Policy Review Date: Annually (January)

1. STATEMENT OF COMMITMENT

Contrarian Path is committed to the highest standards of ethical conduct and compliance. We maintain a zero-tolerance approach to all forms of Modern Slavery, including human trafficking, forced labour, child labour, debt bondage, and servitude, as defined by the Modern Slavery Act 2018 (Cth) and the Queensland Government Supplier Code of Conduct.

This commitment applies to every aspect of our business operations, our employees, and our entire supply chain. We believe in upholding and promoting fundamental human rights and decent working conditions throughout our network.

2. SCOPE AND RESPONSIBILITY
2.1 Scope of Application

This policy applies to:

All employees and officers of Contrarian Path.
All contractors, sub-contractors, and temporary staff engaged by Contrarian Path.
All suppliers and third parties providing goods and services to Contrarian Path, regardless of their geographic location.

2.2 Responsibility and Governance

The Director of Operations holds primary responsibility for the implementation, monitoring, and enforcement of this policy. All staff involved in procurement, human resources, and supplier engagement are responsible for adhering to its principles and reporting any suspected breaches.

3. RISK IDENTIFICATION AND ASSESSMENT
As a digital agency, Contrarian Path’s inherent risk for direct Modern Slavery is generally low. However, we recognise potential risks exist within our extended supply chain. We focus our risk mitigation efforts on the following high-risk areas:

High-Risk Area	Assessment and Mitigation Action
ICT Hardware & Peripherals	Risk: Components sourced from regions with high labour exploitation risk. Mitigation: We prioritise sourcing IT equipment through Australian Tier 1 distributors who publish their own Modern Slavery Statements and provide supply chain transparency.
Outsourced Digital Development/Labour Hire	Risk: Exploitation of offshore or temporary sub-contractors. Mitigation: We include mandatory ethical labour clauses in all sub-contractor agreements and conduct due diligence checks on their stated working conditions and employment standards.
Promotional Goods & Merchandise	Risk: Labour abuse in textile or low-cost manufacturing. Mitigation: Goods are sourced from Australian-certified suppliers or those who can provide clear ethical sourcing documentation for their production facilities.

4. DUE DILIGENCE AND MONITORING
Contrarian Path implements the following due diligence measures:

Supplier Onboarding Vetting: New key suppliers are required to acknowledge and agree to comply with the principles of the Queensland Government Supplier Code of Conduct.
Contractual Requirements: All high-value or high-risk contracts include clauses mandating compliance with anti-modern slavery laws and allowing the QLD Government agency (Customer) or Contrarian Path to seek evidence of compliance.
Supplier Monitoring: We conduct periodic reviews of our critical suppliers’ own policies and statements (where applicable) to ensure continuous commitment to ethical practices.

5. TRAINING AND AWARENESS
Contrarian Path is committed to embedding this policy in our business culture:

Staff Induction: All new employees receive an induction briefing on the Queensland Government Supplier Code of Conduct and this Modern Slavery Statement.
Targeted Training: Annual training will be conducted for staff involved in procurement, human resources, and management to ensure they can identify, escalate, and respond appropriately to modern slavery concerns.

6. REPORTING, WHISTLEBLOWING, AND REMEDIATION

Reporting Mechanism: Any individual (employee, supplier, or sub-contractor) who suspects or becomes aware of a violation of this policy must report it immediately to the Director of Operations or via our confidential internal reporting channel ([Insert Confidential Email/System]).
Non-Retaliation: Contrarian Path strictly prohibits retaliation against anyone who raises concerns in good faith.
Remediation: If a Modern Slavery violation is identified, we will immediately investigate, take swift corrective action (which may include working with the supplier on a remediation plan or terminating the contract), and notify the relevant QLD Government agency within the required contractual timeframe (usually 10 business days).

7. POLICY DECLARATION
Contrarian Path commits to providing evidence of compliance, records, and warranties as reasonably requested by any Queensland Government agency during the procurement process or contract term.

Johnie Bobonica

Managing Director

5th Jan 2026