Modern Day Slavery Policy

Sontext Pty Ltd is opposed to all forms of modern slavery, human trafficking, forced labour, child labour, debt bondage and exploitative employment practices.

Policy Overview

Sontext Pty Ltd is well below the AUD $100 million annual consolidated revenue threshold for mandatory reporting under the Commonwealth Modern Slavery Act 2018.

This Modern Day Slavery Policy is therefore issued voluntarily. It has been prepared because Sontext believes that responsible businesses should take reasonable steps to understand and reduce the risk of modern slavery within their operations and supply chains.

Sontext’s position is straightforward: people involved in the manufacture, supply, transport, installation and delivery of our products must be treated lawfully, fairly and with dignity.

About Sontext Pty Ltd

Sontext Pty Ltd is an Australian-owned company supplying and manufacturing decorative acoustic products for commercial, education, hospitality, healthcare, public building and interior design projects.

Sontext operates from Melbourne, Australia, with commercial activity in Australia, the Middle East, the United States and other export markets.

Our product areas include Serenity fabric acoustic panels, Decrasound PET acoustic panels, Murano acoustic timber panels, Sonofonic painted acoustic ceiling panels and custom decorative acoustic panel systems.

Our Operations and Supply Chains

Sontext’s operations include administration, sales, project coordination, product development, manufacturing, warehousing, dispatch, logistics and supplier management.

Our supply chains include acoustic panel materials, polyester fibre and PET acoustic materials, fabric, timber, veneer, MDF, adhesives, coatings, packaging, freight and logistics services.

Some supply chain activity involves overseas sourcing. Sontext recognises that international supply chains may carry higher modern slavery risks, particularly where there are multiple subcontractors, labour hire arrangements or limited visibility beyond first-tier suppliers.

Modern Day Slavery Risk Areas

Sontext considers the following areas to require ongoing attention:

• overseas manufacturing and raw material sourcing
• freight, logistics and warehousing
• low-cost production pressure within supply chains
• subcontracting and secondary suppliers
• temporary, informal or poorly documented labour arrangements

Sontext’s Commitments

Sontext is committed to:

• complying with Australian employment, workplace health and safety and fair work requirements
• working with suppliers who are expected to operate lawfully and ethically
• refusing to knowingly source from suppliers involved in forced labour, child labour or human trafficking
• taking reasonable steps to understand higher-risk supply chains
• raising concerns directly with suppliers where labour, safety or ethical issues are identified
• reviewing supplier relationships where serious concerns are not addressed

Supplier Expectations

Sontext expects suppliers to comply with applicable labour, safety and employment laws. We expect suppliers to ensure that workers are employed freely, paid lawfully, treated fairly and provided with safe working conditions.

Sontext does not support forced labour, bonded labour, child labour, unsafe work practices or recruitment practices that trap workers in debt.

Where appropriate, Sontext may request information from suppliers about employment practices, production sites, certifications, audit reports or other evidence of responsible conduct.

Due Diligence and Practical Controls

Sontext’s approach is practical and proportionate to the size and nature of the business.

Current and intended controls include:

• selecting suppliers based on quality, reliability and business conduct, not price alone
• maintaining direct relationships with key suppliers wherever possible
• reviewing supplier quality and performance issues as part of broader supplier assessment
• requiring suppliers to address serious quality, safety or conduct concerns
• using documented purchasing and supplier communication processes
• maintaining senior management oversight of key overseas supply relationships
• reviewing supplier relationships where serious concerns arise

Training and Awareness

Sontext will continue to build awareness of modern slavery risks with relevant staff involved in purchasing, supplier management, logistics, sales, project management and senior management decision-making.

The purpose is to help staff recognise warning signs such as unusual supplier behaviour, unexplained subcontracting, poor labour transparency, unrealistic pricing, unsafe production claims or reluctance to provide basic compliance information.

Supporting Anti-Trafficking Work

Sontext recognises that modern slavery is not only a supply chain issue. It is a human issue affecting vulnerable people across many countries and industries.

As part of its broader values, Sontext provides financial support to non-government organisations involved in anti-trafficking and restoration work, including Eden.

Eden works with people who have been trafficked for the purpose of sexual exploitation and provides practical support across areas such as physical, emotional, spiritual, economic and social wellbeing.

Sontext’s financial support for organisations such as Eden reflects our belief that businesses should not only avoid harm in their own operations, but also support practical efforts that assist people affected by exploitation.

Learn more about Eden here:

Eden anti-trafficking work

Measuring Effectiveness

Sontext will assess the effectiveness of this policy by reviewing:

• whether key suppliers remain known and accountable to management
• whether supplier concerns are recorded and followed up
• whether supplier quality and conduct issues are considered together
• whether staff involved in procurement understand modern slavery risk
• whether purchasing decisions continue to reflect ethical and quality considerations, not price alone

Continuous Improvement

Sontext intends to continue improving its approach by:

• strengthening supplier onboarding questions
• adding modern slavery expectations to supplier communications
• reviewing higher-risk overseas supply arrangements
• improving documentation of supplier concerns and corrective actions
• maintaining awareness of Australian modern slavery guidance
• reviewing this policy periodically as the business grows

Approval

This Modern Day Slavery Policy has been prepared for Sontext Pty Ltd and reflects the company’s current position and intended approach to modern slavery risk management.

Sontext is not currently required to submit mandatory modern slavery reporting under the Commonwealth Modern Slavery Act 2018 because its annual consolidated revenue is below the mandatory reporting threshold. This policy is issued voluntarily as part of Sontext’s broader commitment to ethical business conduct.

Approved by:
Gerald Hynes
Managing Director
Sontext Pty Ltd

Policy period: Financial Year 2025–2026
Last reviewed: July 2026