DataTools Anti-Human Trafficking
and Modern Slavery Statement
Purpose
The purpose of this statement is to outline our approach to ensuring that DataTools has the processes in place to minimise the risk of modern slavery in our business operations and supply chain.
At DataTools, we recognise that slavery and human trafficking can occur in many forms, as considered in the Modern Slavery Act. This can include slavery, servitude, human trafficking, forced marriage, forced labour, debt bondage, child labour, and deceptive recruiting for labour or services.
While we believe the risk of modern slavery in our supply chains is low (due to the nature of our services), DataTools remains fully committed to operating responsibly and establishing and adhering to the highest ethical standards. We will not tolerate any forms of slavery or human trafficking in our business.
Our structure, operations and supply chain
Structure
Data Tools Pty Ltd (ABN 21 043 541 385 with its registered address at 310/20a Lexington Dr, Bella Vista NSW 2153 Australia) was recently acquired by GB Group plc (“GBG”) on 16 October 2025. As part of the integration process, DataTools is undergoing a transition period during which its operations, supply chains, and governance frameworks are being aligned with GBG’s modern slavery risk management approach. Further updates on progress will be provided in future reporting periods.
Main operations
DataTools develops and delivers software and cloud services to improve customers’ data quality.
Supply chain
Our supply chain includes:
- Providers of address data; these include but are not limited to postal authorities and government departments.
- Providers of third-party cloud services; these include but are not limited to partners providing address verification, email verification and phone number verification services.
- Providers of cloud infrastructure; these include but are not limited to computing services provided by organisations such as Amazon and Microsoft.
- Contractor and sub-contractors who deliver services such as, but are not limited to, software development and network maintenance.
Our policies
DataTools has policies in place that are intended to promote ethical and legally compliant business conduct. Our policies contribute to our commitment to prevent violations of human rights such as modern forms of slavery in our business.
Our approach
DataTools:
- Conducts modern slavery training as part of its employee onboarding process;
- Reviews modern slavery and trafficking risks for its suppliers.
Our commitment
DataTools will continue to identify and evaluate risks relating to human rights and develop our policies, procedures, and training to help combat modern slavery.
DataTools Anti-Human Trafficking and Modern Slavery FAQ
General
- In what countries does DataTools have operations in? Australia.
- In what countries does DataTools’ suppliers have operations in? Global, including Australia, New Zealand, UK, USA and the Philippines.
- What sectors does DataTools operate in? IT Services & Software.
- Does DataTools employ or hire low-skilled foreign or domestic migrant workers directly or through recruiters? No.
- Does DataTools use recruiters who hire sub-contractors to recruit workers? No.
- Does DataTools or any of its suppliers employ or hire North Korean citizens or nationals, directly or indirectly? No.
Policy Prohibitions
Does DataTools issue policies explicitly prohibiting workers and agents from the following:
- Engaging in all forms of forced labour and human trafficking and modern slavery;
- Engaging in child labour;
- Withholding workers’ identity or immigration documents;
- Using recruiters that do not comply with local labour laws of the country in which the recruiting takes place;
- Charging workers or potential workers recruitment fees?
Yes, see policy below.
Policy Requirements
Does DataTools issue policies explicitly ensuring the following:
- That all documents and agreements in relation to a worker’s employment are in a language that is understood by the workers;
- Workers can cancel their work contracts at any time with no financial penalty, subject to giving reasonable notice in accordance with local laws or agreement;
- Wages meet applicable host country legal requirements;
- Workers (including those hired by recruiters) are provided with detailed and accurate work agreements;
- Document checks including proof of age documents of all workers before they begin working to confirm they are allowed to work according to legal standards and applicable DataTools policies?
Yes, see policy below.
Supply Chain Management
- Does DataTools issue its Anti-Human Trafficking and Modern Slavery policies to its suppliers? Yes.
- Does DataTools require its suppliers to agree to its policies? Yes.
Reporting & Internal Accountability
Does DataTools have a process for workers and agents to report without fear of retaliation, matters relating to slavery and human trafficking? Yes.
Certification
Does DataTools prioritise the use of ethical recruitment agencies certified by credible assurance schemes? Not at this stage, but DataTools is careful to only use recruitment agencies that adhere to the highest ethical standards and align with the values, goals, and objectives of DataTools.
DataTools Anti-Human Trafficking and Modern Slavery Policy
Overview
This policy sets out DataTools’ position against human trafficking and modern slavery.
Scope
This policy applies to DataTools employees and representatives of DataTools and we expect all suppliers, service providers and business partners that DataTools engages to apply similar standards when working with us.
Principles
DataTools is committed to acting ethically and with integrity in all business dealings.
DataTools respects ethical labour practices, values and promotes diversity. Consistent with these principles, DataTools has a zero-tolerance approach to any form of modern slavery in its operations or supply chain. Modern slavery encompasses servitude, forced labour, debt bondage and human trafficking.
All employees, contractors, suppliers, service providers, business partners and agents must not engage in any practices of modern slavery or human trafficking, and must take reasonable steps to identify, assess, and address risks of modern slavery in its supply chains.
Where a supplier or contractor uses a sub-contractor, they must ensure adequate processes are in place to ensure that subcontractors also operate in accordance with this policy.
Below are the minimum standards expected by DataTools.
Minimum Standards
No forced labour
This policy sets out DataTools’ position against human trafficking and modern slavery.
Employment must be freely chosen. No worker should be subjected to:
- forced labour, where work or service is extracted under the menace of any penalty;
- bonded labour, work which is not for compensation received by the worker, but to repay a debt, often incurred by another person offering the worker’s labour in exchange;
- indentured labour, where an employer forbids workers from leaving employment at the worker’s discretion.
Freedom of movement
Workers’ movement must not be restricted by controlling identity papers, immigration documents, holding money deposits, or taking any action to prevent workers from terminating their employment. Workers must be free to leave their employer after reasonable notice.
No child labour
Work must not be performed by children under the minimum legal working age in the country of employment. Where no minimum legal age exists, no work should be carried out by a child under the age of 15.
Wages and compensation
Workers must receive at least all wages, overtime compensation, and benefits mandated by local laws. Workers must be provided with written and understandable information about their employment conditions before entering employment, and about their wages for each pay period. Deductions from wages for disciplinary measures or other deductions not provided by law must not occur without the worker’s express permission. All disciplinary measures should be recorded.
Working hours
Working hours must comply with applicable local laws. Workers should not be required to work more than the maximum hours per week allowed by law. Overtime must be voluntary and not excessive.
No discrimination
All conditions of employment must be based on an individual’s ability to perform the job, not personal characteristics such as gender, ethnic origin, religion, age, disability, beliefs, marital status, sexual orientation, union membership, or political affiliation. Work environments should be free from harassment, discrimination, or other inappropriate workplace behaviour.
No harassment or abuse
Workers must be treated with dignity and respect. Workplaces must be free from physical, sexual, verbal, or visual harassment or any behaviour that creates an offensive, hostile, or intimidating environment.
Working conditions
Workplaces must be safe and hygienic, without risk to health. Workers must receive adequate and regular training to perform their jobs safely. Personal protective equipment and machinery safeguards must be provided, and workers trained in their use. Workers must have access to clean toilet facilities, clean drinking water, and sanitary facilities for food storage and preparation where applicable. Workers have the right to refuse unsafe work.
Hiring and regular employment
Workers must be provided with a clear, understandable, detailed, and accurate labour contract containing all legally required employment terms, entitlements, and conditions. Workers must not be charged recruitment fees.
Recruiters must comply with all local laws and must not use sub-contractors to recruit workers. All worker documents must be checked before work begins to confirm age and ensure compliance with local laws and DataTools policies.
Before relocation, workers must receive a detailed and accurate work agreement. All employment documents and agreements must be in a language the worker understands.
Workers must be able to cancel their work contracts at any time with no financial penalty, subject to giving reasonable notice in accordance with local laws or their employment agreement.
Breaches of this Policy
All DataTools workers are able to report to HR, without fear of retaliation, any suspected misconduct, including matters relating to labour practices, slavery, human trafficking and human rights.
All suspected breaches will be investigated, and appropriate disciplinary and remedial action taken.
Employees who do not strictly comply with this policy may face disciplinary action, including formal warnings and termination. Suppliers, contractors and sub-contractors who do not strictly comply with this policy may face termination of their contracts and discontinuation of their business with DataTools.
