Modern Slavery Statement

SUMO Holdings Pty Ltd and its subsidiaries (collectively, "SUMO") are committed to operating ethically and with integrity across all business activities, relationships, and supply chains. We have zero tolerance for modern slavery, forced labour, human trafficking, servitude, deceptive recruitment practices, and any form of worker exploitation within our operations and supply chains.

Although SUMO is not currently required to report under the Modern Slavery Act 2018 (Cth), we have prepared this statement voluntarily in response to client, procurement, and stakeholder expectations, and to demonstrate our commitment to responsible business practices.

SUMO provides offshore staffing and managed services to Australian businesses. Our model enables clients to build and operate offshore teams, primarily in the Philippines, across professional and administrative functions.

SUMO operates under an employment-based model (commonly delivered through an Employer of Record (EOR) or managed services arrangement), where workers are directly employed by SUMO Services Corporation, our Philippines-based employing entity, under a structured and compliant local employment framework. This enables SUMO to maintain oversight of employment conditions, worker welfare, and regulatory compliance.

Our core services include:

• Recruitment and onboarding
• Payroll management and HR administration, encompassing compensation and benefits, statutory compliance and regulatory requirements, and employment governance
• Technology enablement and equipment provisioning
• Service delivery and operational oversight

As a provider of labour-related services, we recognise that our sector carries elevated modern slavery risks if not properly managed.

We recognise that modern slavery risks are more likely to arise in our labour-related arrangements and third-party service relationships, rather than in our direct Australian corporate activities.

Key risk areas include:

1. Recruitment Practices
   Risk of misrepresentation of employment conditions or undue pressure on workers during the hiring process.

2. Employment Conditions and Wage Practices
   Risk of unlawful or unexplained deductions from wages, or inadequate wage benchmarking resulting in underpayment relative to local market standards.

3. Worker Autonomy and Freedom
   Risk of coercive employment practices, barriers to resignation, or any undue restriction on worker freedom.

4. Third-Party Recruiters and Intermediaries
   Risk arising from the use of third-party recruiters or intermediaries without appropriate due diligence and oversight.

5. Worker Grievance and Reporting Mechanisms
   Risk of inadequate or inaccessible channels for workers to raise concerns or report misconduct.

Additional risk areas:

• Misclassification or engagement structures that may obscure true employment relationships or entitlements.

SUMO addresses these risk areas through structured controls embedded within our operating model:

1. Recruitment Practices
   • Standardised, in-house recruitment processes to ensure transparency and consistency
   • Clearly defined role requirements, compensation, and employment terms prior to engagement
   • Formal employment contracts aligned with Philippine labour laws
2. Employment Conditions and Wage Practices
   • Compensation benchmarked against Philippine market rates
   • Centralised payroll with full internal visibility and control over salary, benefits, and statutory contributions
   • Compliance with all applicable statutory and regulatory requirements
3. Worker Autonomy and Freedom
   • Clearly defined employment terms, including fair resignation processes
   • No retention of personal documents or restriction on freedom of movement
   • HR oversight to ensure fair and compliant employment conditions
4. Third-Party Recruiters and Intermediaries
   • Primary reliance on in-house recruitment to maintain control over hiring standards and candidate engagement
   • Due diligence applied where third parties are engaged
   • Clear expectations for ethical recruitment practices and compliance
5. Worker Grievance and Reporting Mechanisms
   • Direct access to HR and management for issue escalation
   • Established escalation pathways and timely resolution processes
   • A safe reporting environment without fear of retaliation

Additional control measures:

• All personnel are engaged under SUMO Services Corporation within a structured and compliant employment framework.

SUMO is committed to maintaining a workplace where workers are treated with dignity and respect and can raise concerns in a safe and confidential environment.

Workers and relevant stakeholders may raise concerns through HR or management channels.

SUMO will:

• Assess concerns promptly
• Investigate matters appropriately
• Take corrective action where required
• Review whether broader control improvements are necessary

Where concerns involve third parties, SUMO will review the relationship and take appropriate action, including discontinuation where necessary.

SUMO works with clients, partners, and service providers who share our commitment to ethical business practices.

Our approach includes:

• Assessing recruitment channels and service providers
• Reviewing contractual arrangements and onboarding processes
• Raising concerns where practices are inconsistent with applicable laws and ethical labour standards
• Updating internal processes where new risks are identified

Due diligence is an ongoing process that continues to evolve as our business grows.

Responsibility for oversight of modern slavery risk management sits with SUMO executive leadership, including accountability for monitoring, review, and continuous improvement of the controls and practices outlined in this statement.

SUMO reviews and updates this statement annually as part of its ongoing commitment to managing modern slavery risks.