First Contact – Modern Slavery Statement 2025

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Introduction

First Contact Pty Ltd (ACN 158 830 301) is committed to eliminating modern slavery and unethical labour practices in all forms across our operations and supply chains. As a leading provider of workplace services and workforce solutions, we recognise our responsibility to uphold human rights, fair employment standards, and ethical business practices.

This statement is made in accordance with the Australian Modern Slavery Act 2018 and outlines the measures we take to assess, prevent, and mitigate modern slavery risks. As a registered and licensed labour hire provider in Victoria (VICLHL03915) and Queensland (LHL-05737-V4P5Z), we ensure full compliance with:

• Labour Hire Licensing Act 2017 (Victoria)
• Labour Hire Licensing Act 2018 (Queensland)
• Fair Work Act 2009 and the National Employment Standards (NES)
• Migration Act 1958 for visa worker protections

Our approach aligns with B-Corp principles, our broader Environmental, Social, and Governance (ESG) commitments, and international human rights frameworks, including the United Nations Guiding Principles on Business and Human Rights (UNGPs) and International Labour Organisation (ILO) standards.

Our Business, Operations, and Supply Chains

First Contact Pty Ltd provides workplace services, workforce solutions, and business support to leading corporate occupiers and commercial property owners across Australia. Our services include:

• Workforce solutions, including recruitment, placement, and labour hire
• Workplace management, concierge, and front-of-house operations
• Facilities and vendor management, including food and beverage partnerships^[a]
• Office activation, project management, and workplace technology

As a company primarily supplying workforces, we have a heightened responsibility to protect worker rights and uphold ethical employment standards. Our supply chain consists of contracted service providers, third-party labour suppliers, technology vendors, and procurement partners, making modern slavery risk management a critical priority. 

Governance and Policies

First Contact has implemented a robust governance framework to prevent modern slavery, ensure fair work practices, and hold all stakeholders accountable. Our key policies include:

• Code of Conduct – Defines ethical business standards, human rights protection, and responsible employment practices.
• Supplier Code of Conduct – Mandates compliance with Fair Work Australia standards, ethical recruitment practices, and modern slavery prevention.
• Labour Hire Licensing Compliance Framework – Ensures all staffing operations meet strict Victoria and Queensland labour hire regulations.
• Whistleblower Protection Policy – Provides confidential reporting channels for employees and external parties to raise concerns about unethical labour practices.
• Fair Work Compliance Policy – Guarantees that all labour hire and directly employed workers receive their full legal entitlements, including fair wages, leave entitlements, and safe working conditions.
• Migration Act Compliance – Ensures that all workers, including those on temporary visas, have verified work rights and receive fair treatment under Australian employment laws.

All supplier agreements contain modern slavery compliance clauses, ensuring that our entire supply chain operates with transparency and accountability.

Risk Assessment and Due Diligence

To proactively identify, assess, and mitigate modern slavery risks, First Contact applies a risk-based approach to workforce management and supply chain oversight. Our due diligence process includes:

Workforce Risk Assessments

• Verifying legal work entitlements for all employees and labour hire staff.
• Ensuring fair wages, safe working conditions, and equal treatment across all employment arrangements.
• Preventing forced labour, deceptive recruitment, and unfair deductions in any staffing contract.
• Ensuring that all workers, including temporary visa workers, are employed in compliance with the Migration Act 1958.

Supplier Due Diligence and Monitoring

• Conducting risk assessments of suppliers based on sector, geography, and labour intensity.
• Requiring all suppliers to sign modern slavery compliance clauses in contracts.
• Implementing mandatory supplier reporting on labour practices and workforce conditions.
• Conducting independent audits of high-risk suppliers, particularly in facilities management, cleaning, and outsourced staffing services.

High-Risk Industry and Supply Chain Controls

Certain industries present elevated risks of modern slavery. First Contact implements additional scrutiny in sectors such as:

• Labour hire and outsourced recruitment – Ensuring fair treatment of all contracted workers.
• Cleaning and facility services – Monitoring compliance with Fair Work Awards and ethical labour standards.
• Procurement and product sourcing – Prioritising sustainably sourced and ethically produced materials.

By applying stringent due diligence, we ensure that modern slavery risks are identified, mitigated, and continuously monitored. 

Training, Awareness, and Worker Empowerment

Employee Training Programs

• Regular mandatory training for all employees and managers on modern slavery risks.
• Specialised recruitment training for HR and workforce managers on ethical hiring and fair work practices.
• Onboarding education for labour hire workers, ensuring they understand their rights, entitlements, and reporting channels.

Supplier Engagement and Capacity Building

• Collaboration with third-party suppliers to improve their modern slavery compliance practices.
• Provision of training and guidance materials to help suppliers adopt ethical labour standards.
• Regular supplier forums to address emerging risks and compliance expectations.

Worker Protection and Reporting Mechanisms

• Strengthening worker grievance channels to provide direct, anonymous avenues for reporting unfair treatment or exploitative conditions.
• Ensuring all employees can safely report modern slavery risks without retaliation.

Collective Bargaining and Industrial Relations Engagement

• First Contact recognises the right of employees, including labour hire workers, to collective bargaining and representation in line with the Fair Work Act 2009.
• We actively engage with trade unions, employer associations, and industry regulators to strengthen ethical employment practices across our workforce supply chains.

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Monitoring, Reporting, and Continuous Improvement

Modern slavery risk management is not a one-time exercise, but an ongoing process of improvement and accountability. First Contact ensures:

• Annual Policy and Compliance Reviews – Continuous evaluation of risk assessments, supplier audits, and governance frameworks.
• Board Oversight and ESG Integration – Ensuring modern slavery prevention remains a strategic business priority.
• Independent Supplier Audits – Strengthening oversight on high-risk suppliers in workforce and facilities management industries.
• Public ESG and Modern Slavery Reporting – Publishing transparent annual reports on modern slavery prevention progress.

As we progress towards B-Corp certification, we will enhance supplier oversight, expand training initiatives, and refine risk mitigation strategies to ensure industry-leading compliance. 

Conclusion

First Contact Pty Ltd is fully committed to eliminating modern slavery from its operations and supply chains. As a workforce solutions and workplace services provider, we understand the critical responsibility of protecting workers’ rights, preventing exploitation, and enforcing ethical labour practices.

With strong governance, supplier accountability, workforce due diligence, and continuous risk monitoring, we ensure that modern slavery has no place in our business.

This statement has been approved by the Board of Directors and will be reviewed annually to ensure compliance with Australian law, ESG commitments, and modern slavery prevention best practices.

Signed,

John Gregory Ortner, PhD
CEO & Managing Director
First Contact Pty Ltd
Date: 1st January 2025

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