Modern Slavery and Ethical Sourcing Statement

Aperim Pty Ltd (ABN 46150699737; ACN 150699737) is incorporated in New South Wales, Australia and operates the aicial brand. In this statement, “aicial” refers to that brand; “we”, “us” and “our” refer to Aperim Pty Ltd; and “you” refers to a reader of this statement, including a supplier, business partner or member of the public.

This statement describes the risk of modern slavery — forced labour, child labour, debt bondage and related practices — in our operations and supply chain, what we do to identify and address that risk, and how to raise a concern.

The Modern Slavery Act 2018 (Cth) requires an entity with a consolidated revenue of at least AUD 100 million for a reporting period, and that is an Australian entity or carries on business in Australia, to prepare and lodge an annual Modern Slavery Statement. Aperim Pty Ltd’s consolidated revenue is far below that threshold. We are not a reporting entity under the Act, and we are not legally required to lodge a Modern Slavery Statement.

We publish this statement voluntarily because identifying and addressing modern slavery risk is the right thing to do, regardless of a legal size threshold, and because the Act’s own framework contemplates and provides for voluntary reporting by entities below the mandatory threshold. As an early-stage company, we would rather set this expectation now, while our supply chain is simple, than wait until our size or the law requires it.

Our supply chain is small and concentrated. We are a services company, not a goods company: we do not manufacture, sell or distribute physical products, and we do not have a manufacturing, agricultural, textile or other physical-goods supply chain of the kind that typically presents the highest modern slavery risk.

Our technical infrastructure runs on Cloudflare: hosting and compute (Cloudflare Workers), our database (Cloudflare D1), bot and abuse protection on our forms (Cloudflare Turnstile), and Cloudflare’s own Email Service for transactional email. Cloudflare is, in practical terms, our only current infrastructure vendor. It is a large, established, publicly listed technology company that is itself subject to significant public and regulatory scrutiny.

Beyond Cloudflare, our current vendor base is limited to the ordinary professional and administrative services a small company uses, such as software tools and professional advisers.

We will not knowingly engage a supplier, vendor or business partner that uses forced labour, child labour, debt bondage or any other form of modern slavery, in any part of its own operations or supply chain.

Where we identify a credible risk that a supplier, vendor or business partner is engaged in, or exposed to, modern slavery, we will assess that risk and take proportionate action in response. Depending on the circumstances, that action may include seeking further information, requiring remediation, or ending the relationship. We treat ending a relationship as a genuine option, not a last resort we are unwilling to use.

We assess the risk in our own operations as low. Everyone who works for us is engaged directly, either as an employee or under a standard contractor arrangement that we hold to the commitments in our Human Rights Policy. We do not use a labour-hire firm, recruitment intermediary or other outsourced staffing arrangement to obtain labour for our operations, which are among the arrangements associated with a heightened risk of modern slavery.

We also assess our current modern slavery risk in our supply chain as low. That reflects who we are today: an early-stage services company with a small vendor base concentrated in cloud infrastructure, rather than a company that sources hardware, physical goods, or maintains a large or geographically diverse supplier base.

We will reassess this risk as our company grows, including our own operations if how we engage our people changes, and our supply chain if and when we begin sourcing hardware, physical goods or a materially larger vendor base, and we will update this statement to reflect that reassessment.

Our Supplier and Vendor Code of Conduct sets out the standards we expect from anyone we engage as a supplier, vendor or business partner, including on modern slavery, labour standards and ethical conduct. We expect every supplier, vendor and business partner to meet that Code, and we take a supplier’s willingness to meet it into account before and during an engagement.

Aperim Pty Ltd is an early-stage company. Accountability for the commitments in this statement currently sits with Aperim Pty Ltd’s leadership rather than a separate or formally constituted body.

As aicial grows, we will formalise this governance — including clearer internal roles and a defined review process — proportionate to the size and complexity of our supply chain at the time, and we will update this statement when we do.

If you believe a supplier, vendor or business partner engaged by us is connected to modern slavery, contact compliance@aicial.com with as much detail as you can provide. We acknowledge and investigate a concern raised under this statement within a reasonable period and tell you what we found and what, if anything, we are doing about it.

You can also raise a concern under our Whistleblower and Ethics Policy, which is open to anyone — including a supplier’s workforce and members of the public — and explains how a report is handled, including the option to report anonymously and our commitment not to retaliate against a good-faith report.

We review this statement at least annually, and whenever our supply chain changes materially, such as engaging a materially different kind of supplier or vendor. The version, effective date and last-reviewed date shown at the top identify the current statement.

For questions about this statement, or to raise a modern slavery concern, contact:

Aperim Pty Ltd, which operates the aicial brand
ABN 46150699737
ACN 150699737
New South Wales, Australia
Email: compliance@aicial.com