DataTools Modern Slavery Statement and Policy

DataTools Anti-Human Trafficking and Modern Slavery Statement

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.

DataTools is 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.

Even though DataTools is not required to comply with the Modern Slavery Reporting Requirement we believe there is a moral obligation to support the Act. DataTools provides this voluntary statement to assist our customers in their reporting obligations.

Our structure, operations and supply chain

Data Tools Pty Ltd is 100% privately owned Australian company, ABN 21 043 541 385 with its registered address at 310/20a Lexington Dr, Bella Vista NSW 2153.

Main operations

DataTools develops and deliver software and cloud services to improve customers data quality.
Supply chain

– 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 partner 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 have 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 uses the open-source industry standard template Slavery & Trafficking Risk (STRT) to assist in ensuring its suppliers, contractor and sub-contractors are complying with human trafficking and modern slavery legislation.

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

– In what countries does DataTools have operations in? Australia
– In what countries does DataTools’ suppliers have operations in? 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 Questions

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? Yes, see policy below.
– Engaging in child labour? Yes, see policy below.
– Withholding workers identity or immigration documents? Yes, see policy below.
– Using recruiters that do not comply with local labour laws of the country in which in the recruiting takes place? Yes, see policy below.
– Charging workers or potential workers recruitment fees? Yes, see policy below.
– Procuring commercial sex acts? Yes, see policy below.
– Does DataTools issue polices 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? Yes, see policy below.
– Provision or payment of transport for foreign migrant workers? N/A, DataTools do not hire any foreign workers.
– Housing provided or arranged for workers meets safety standards? N/A, DataTools do not provide or arrange housing.
– 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? Yes, see policy below.
– Wages meet applicable host country legal requirements? Yes, see policy below.
– Workers (including those hired by recruiters) are provided with detailed and accurate work agreements or similar work papers prior to relocation? Yes, and this applies to all workers weather or not required by law, see policy below.
– Document checks including proof or 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 polices to its suppliers? Yes, policy is below.
– Does DataTools have contractual terms and conditions that require its suppliers to affirmatively agree to its policies? Only where the supplier is not already required by law to comply with the Modern Slavery Act.

Risk Identification and Management

– Does DataTools perform screening and evaluation of prospective recruiters to determine if they operate in compliance with the law and applicable organisation policies and observe the employment pay principle of not charging and recruitment fees to workers?
Yes, DataTools requires all recruiters to agree with DataTools Anti-Human Trafficking and Modern Slavery polices, see policy below.
– Does DataTools engage in due diligence activities to identify, present and mitigate risks specific to slavery and human trafficking in the following areas: your operations, your direct supply chain, your indirect supply chain and your labour supply chain? Yes, DataTools uses the open-source industry standard template Slavery & Trafficking Risk (STRT) to assist in identifying, presenting
and mitigating risks in relation to slavery and human trafficking.


– Do DataTools workers who have direct responsibility for supply chain management and recruitment receive training on how to mitigate risk of slavery and human trafficking? Yes, training is provided in the use of the Slavery & Trafficking Risk (STRT) system and how to use the system to score responses and identify risk.

Reporting & Internal Accountability

– Does DataTools have a process for workers and agents to report without fear or retaliation, matters relating to the slavery and human trafficking? Yes, DataTools uses an external service provider to enable workers to anonymously report without fear any suspected misconduct, including matters relating to labour practices and human rights.


– 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


This policy sets out DataTools’ position against human trafficking and modern slavery.


This policy applies to DataTools employees and representatives of DataTools and we expect all contractors, subcontractors and business partners that DataTools engages to apply similar standards when working with us.


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, suppliers, contractors and sub-contractors must not engage in any practices of modern slavery or human trafficking. Below are the Minimum Standards expected by DataTools.

Where a supplier or contractor uses a sub-contractor they must make sure adequate processes are in place to ensure that subcontractors also operate in accordance with this policy.

DataTools Minimum Standards

No forced labour

Employment must be freely chosen. No Worker in any way should be:
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, which is 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 the controlling of identity papers, holding money deposits or taking any other 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 a minimum legal age is absent in the local laws, no work should be carried out by a child under the age of 15.

Wages and compensation

Workers must receive (at a minimum) all wages, overtime compensation and benefits mandated by local laws. Workers must be provided with written and understandable information about their employment conditions before they enter employment and about their wages for each pay period. Deductions from wages for disciplinary measures or any deductions from wages not provided for by law shall not occur without the express permission of the worker concerned. 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 as stipulated by local laws. Overtime shall be agreed and not excessive.

No discrimination

All conditions of employment must be based on an individual’s ability to do the job, not on the basis of personal characteristics, such as gender, ethnic origin, religion, age, disability, personal beliefs, marital status, sexual orientation, union membership or political affiliation. The work environments should be without distress or interference caused by harassment, discrimination or any other inappropriate
workplace behaviour.

No harassment or abuse

Workers shall be treated with dignity and respect. Workplaces must be free from harassment, including physical, sexual, verbal or visual behaviour that creates an offensive, hostile or intimidating environment.

Working conditions

Workplaces must be a safe and hygienic environment that is without risk to health.
Workers shall receive adequate and regular training to perform their jobs in a safe manner.
Personal protective equipment and machinery safeguards shall be supplied, and workers trained in their use. Workers will have access to clean toilet facilities, clean drinking water and, where appropriate, sanitary facilities for food storage and preparation. Workers have the right to refuse work that is unsafe.

Hiring and regular employment

Workers must be provided with a clear, understandable labour contract containing all legally required employment terms, entitlements and conditions. Workers must not be charged any recruitment fees for their employment.
Recruiters must comply with all local labour laws.
Documents of all Workers must be checked before they begin work to confirm their age to ensure that they are allowed to work according to the local laws and DataTools policies.
Prior to any relocation workers must be provided with a detailed and accurate work agreement.
All documents and agreements in relation to a Workers employment must be in a language that is understood by the Worker.

Breaches of this Policy

DataTools uses an external service provider to enable workers to anonymously report without fear any suspected misconduct, including matters relating to labour practices 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.

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