Modern
Slavery
Statement

Policy statement

Nexus Interiors Australia Pty Ltd (Nexus) is committed to respecting human rights and reducing the risk that modern slavery occurs in our operations, in the manufacture and sourcing of the products we supply, or in the services used to deliver workplace projects.

Our approach is risk-based, practical and focused on continuous improvement. Nexus will not knowingly tolerate modern slavery and will respond in a way that prioritises the safety and interests of affected people.

1.    Purpose and scope

This policy sets out how Nexus identifies, assesses and addresses modern slavery risks in its operations and supply chains. It is intended to support responsible purchasing, supplier engagement, contract management, project delivery, escalation and remediation.

It applies to all Nexus directors, officers, employees, labour hire and agency workers, contractors and consultants. Nexus also expects suppliers, manufacturers, distributors, logistics providers, installers, subcontractors and other business partners to act consistently with this policy and applicable laws.

2.    What modern slavery means

Modern slavery describes serious exploitation where a person cannot refuse or leave work because of threats, coercion, deception, abuse of power or other forms of control. It can include:

• slavery, servitude and forced labour
• debt bondage and deceptive recruitment
• human trafficking
• the worst forms of child labour
• forced marriage, where relevant to a person’s exploitation
• conduct involving confiscation of identity documents, restriction of movement, excessive recruitment fees, withholding of wages or threats against workers or their families

Modern slavery is different from poor working conditions or underpayment, although these may be warning signs, may breach workplace laws, and can increase vulnerability to exploitation.

3.    Nexus operations and supply-chain context

Nexus supplies office furniture and related workplace products and services. Modern slavery risks may arise beyond Nexus’s direct suppliers, including at raw-material, component-manufacturing and labour-subcontracting levels.

Priority risk areas for an office furniture supplier

 

Category	Examples	Potential risk factors
Materials and components	Timber and wood products; metals; stone; glass; plastics; foam; adhesives; textiles; leather; electrical components and accessories.	Limited visibility beyond tier-one suppliers; raw materials sourced from higher-risk locations; commodity processing; home-based or informal work.
Manufacturing	Furniture, joinery, seating, fabrics, workstations, storage and accessories manufactured locally or overseas.	Migrant or temporary labour; recruitment fees; excessive overtime; wage withholding; restricted movement; unauthorised subcontracting.
Logistics and warehousing	Freight forwarding, shipping, ports, warehousing and last-mile delivery.	Complex subcontracting; labour hire; time pressure; vulnerable workers; limited oversight of lower-tier providers.
Installation and fitout support	Installers, trades, site labour, assembly, removal and relocation services.	Labour hire and subcontracting chains; sham contracting; cash payments; poor records; compressed project timelines.
Corporate procurement	Cleaning, uniforms, electronics, promotional goods and facilities services.	Low-cost procurement, outsourced labour and opaque supply chains.

 

4.    Guiding principles

People first. Responses should protect affected or potentially affected people and avoid actions that may increase harm.

Risk-based due diligence. Nexus will prioritise the most severe and likely risks, rather than relying only on supplier location or spend.

Engagement before disengagement. Where safe and appropriate, Nexus will work with suppliers to prevent, mitigate and remediate harm. Ending a relationship may be necessary where a supplier refuses to cooperate, but should not be automatic if it could worsen harm to workers.

No retaliation. A person who raises a concern in good faith must not be disadvantaged for doing so.

Continuous improvement. Nexus recognises that supply-chain visibility develops over time and will document progress, gaps and next steps honestly.

5.    Governance and responsibilities

 

Accountable party	Core responsibility
Directors / senior management	Approve this policy; oversee material risks and responses; allocate appropriate resources; review effectiveness.
Procurement and project leads	Apply supplier due diligence; include proportionate contract requirements; maintain records; monitor risks throughout delivery.
Managers	Ensure teams understand this policy and escalate concerns promptly.
Workers and contractors	Complete required training; remain alert to warning signs; report concerns; cooperate with reviews and investigations.
Suppliers and business partners	Comply with applicable laws; communicate expectations through their own supply chains; provide accurate information; notify Nexus of suspected modern slavery; cooperate with corrective action and remediation.

 

6.    Risk-based supplier due diligence

Nexus will apply due diligence proportionate to the nature, severity and likelihood of the risk. The process may include the following steps:

1. Screen and prioritise: Consider product category, materials, manufacturing location, workforce profile, subcontracting, recruitment practices, supplier transparency, adverse information and business leverage.

2. Obtain information: Use supplier questionnaires, declarations, policies, certifications and supply-chain mapping. Requests should be targeted and not treated as proof on their own.
3. Assess controls: Consider whether the supplier has credible worker protections, grievance channels, recruitment-fee controls, wage and hours records, subcontractor oversight and remediation processes.

4. Set expectations: Include modern slavery and human-rights requirements in onboarding documents or contracts where proportionate, including notification, information, audit and corrective-action provisions.
5. Verify higher risks: Where warranted, seek further evidence, conduct interviews or site visits, commission an independent review, or require a time-bound corrective-action plan.
6. Monitor and review: Refresh due diligence periodically and when there is a material change, credible allegation, new product category, new manufacturing site or significant subcontracting change.

7.    Minimum supplier expectations

Nexus expects suppliers and business partners to:

• prohibit modern slavery and comply with applicable labour, human-rights and workplace laws
• ensure work is freely chosen and workers can leave employment lawfully without improper penalty
• not charge workers recruitment fees and, where identified, support repayment through an appropriate remediation process
• not retain passports or identity documents except where legally required and genuinely voluntary, with worker access at all times
• provide clear employment terms in a language workers understand and pay wages accurately and on time
• maintain lawful working hours and rest arrangements
• prevent unlawful child labour and protect young workers
• provide safe, accessible and non-retaliatory grievance channels
• conduct due diligence on their own suppliers and subcontractors, with particular attention to unauthorised subcontracting
• promptly notify Nexus of credible modern slavery concerns connected with products or services supplied to Nexus
• preserve relevant records and cooperate with proportionate information requests, corrective action, reviews and remediation

8.    Warning signs

Indicators do not prove modern slavery, but one or more may justify further inquiry. Examples include:

• workers appear unable to leave a workplace or accommodation
• identity documents are held by an employer, recruiter or labour broker
• workers owe recruitment-related debts or deductions are unexplained
• wages are withheld, delayed, paid to another person, or materially different from promised terms
• workers are coached, monitored or prevented from speaking privately
• accommodation, transport or employment is controlled in a way that restricts movement
• supplier information is inconsistent, repeatedly incomplete or conceals manufacturing locations or subcontractors
• prices or lead times appear unrealistic without explanation
• young-looking workers are present in hazardous work or required documentation is absent

9.    Reporting concerns and escalation

Anyone may raise a concern with their manager, the Managing Director, or another senior leader they trust. Concerns may be raised confidentially. Nexus will handle personal information carefully and limit disclosure to those who need it to assess and respond.

If there is an immediate threat to life or safety, contact emergency services. Nexus should also consider specialist, legal or law-enforcement referral where appropriate and safe. A concern should not be confronted in a way that could endanger a potentially affected person or compromise evidence.

10.   Responding to suspected modern slavery

Nexus will respond in a manner proportionate to the allegation and its connection to the harm. A response may include:

• recording and triaging the concern promptly
• protecting confidentiality and assessing immediate safety risks
• seeking appropriately qualified legal, human-rights or specialist advice
• engaging the supplier without alerting alleged perpetrators where that could increase risk
• preserving relevant documents and establishing the facts
• agreeing a corrective-action plan with responsibilities, milestones and verification
• using leverage to prevent or mitigate harm
• supporting or enabling remedy where Nexus caused or contributed to harm, and cooperating with legitimate remediation processes where Nexus is directly linked to harm
• suspending orders, restricting new work, or terminating the relationship where risks cannot be responsibly managed or the supplier refuses to act

Remediation should be designed around the needs and safety of affected people. Nexus will avoid relying solely on financial reimbursement, contract termination or an audit closure where broader action is needed to address harm.

11.   Training, records and monitoring

Nexus will provide role-appropriate awareness or training to personnel involved in procurement, supplier management, project delivery and escalation. Training should explain relevant risks, warning signs, reporting channels and practical responsibilities.

Nexus will maintain proportionate records of supplier screening, risk assessments, information received, decisions, corrective actions, grievances and review outcomes, subject to privacy, confidentiality and legal requirements.

Effectiveness measures

Nexus may use qualitative and quantitative indicators to test whether this policy is working, such as:

• coverage and quality of supplier risk screening
• higher-risk suppliers reviewed and actions completed
• supplier engagement and improvement over time
• training completion for relevant roles
• concerns raised, response timeliness and outcomes, without discouraging reporting
• recurring themes, control gaps and lessons incorporated into procurement and project processes

Measures should be interpreted carefully. For example, a low number of reports does not necessarily mean low risk; it may indicate limited awareness or inaccessible reporting channels.

12.   Breaches and consequences

A breach of this policy by a worker may result in action under applicable workplace procedures and law. A supplier or business partner that breaches this policy may be required to implement corrective action and may face suspension, restriction or termination of the relationship, depending on severity, cooperation, remediation and the potential impact on affected people.

13.   Review, approval and publication

This policy will be reviewed at least annually and earlier where there is a material change in law, operations, sourcing, risk profile or lessons from an incident. Material amendments require approval by the directors or senior management.