PromoSpark Modern Slavery Policy

Effective Date: 1 July 2025

PromoSpark (a division of Premedia Marketing Production Services Pty Ltd, ABN 61 647 912 150) is committed to operating ethically and responsibly across all aspects of our business. We reject any form of modern slavery and are dedicated to ensuring that our operations and supply chains are free from practices such as human trafficking, forced labour, child labour, servitude, and debt bondage.

This Policy outlines our obligations under the Modern Slavery Act 2018 (Cth) and reflects our proactive approach to protecting human rights within our business and among our partners.

1. Structure, Operations & Supply Chain

PromoSpark is a branded merchandise and marketing production company operating under Premedia Marketing Production Services Pty Ltd. We source, customise, and distribute promotional products, signage, and retail marketing materials. Our operations involve:

• Local and international suppliers of blank products and promotional goods
• Australian-based creative, production, and logistics partners
• Warehousing, fulfilment, and delivery services within Australia

Our supply chain includes both Australian distributors and international manufacturers, primarily based in Asia, Europe, and North America.

2. Identifying Risks of Modern Slavery

We recognise that some areas of our supply chain present higher risks of modern slavery, especially where:

• Manufacturing occurs in countries with less regulated labour laws
• There is limited transparency from third-party intermediaries
• Raw materials (such as cotton, rubber, electronics) are sourced from high-risk regions

We consider potential exposure across:

• Apparel and textile supply chains
• Electronics and branded tech products
• Logistics and third-party distribution services

3. Actions to Assess & Address Risk

To mitigate risks, PromoSpark has implemented the following measures:

• Supplier Vetting: We assess suppliers during onboarding to evaluate their compliance with ethical labour standards.
• Contractual Terms: All suppliers must adhere to our Supplier Code of Conduct, which prohibits forced labour and child labour.
• Ethical Sourcing Policy: Preference is given to suppliers with third-party certifications such as Sedex, BSCI, SA8000, or WRAP.
• Ongoing Engagement: We encourage dialogue with suppliers and customers to improve transparency and traceability.
• Sample Audits: For higher-risk product categories, we may request audits or compliance declarations.

4. Monitoring, Evaluation & Effectiveness

PromoSpark is committed to continual improvement in monitoring risks and enhancing accountability. We evaluate effectiveness through:

• Supplier self-assessment checklists and declarations
• Periodic reviews of supplier performance and compliance
• Tracking modern slavery legislation updates and best practices
• A dedicated compliance officer to oversee progress

This policy and our processes will be reviewed annually prior to the end of each financial year.

5. Grievance Mechanisms

We are committed to providing accessible grievance channels for all stakeholders. Any staff member, supplier, or third party may report modern slavery concerns via:

• Email: hello@promospark.com.au
• Phone: 1800 571 825
• Confidential reporting form: Available upon request

All reports are handled with discretion and escalated internally for investigation. Retaliation against whistleblowers is strictly prohibited.

6. Training & Awareness

PromoSpark will ensure that employees, especially those involved in procurement, supply chain management, and operations, receive regular training on:

• Recognising the signs of modern slavery
• How to raise concerns
• Ethical sourcing requirements

Suppliers will be encouraged to promote similar awareness within their own organisations.

7. Commitment to Continuous Improvement

We will continue refining our processes, policies, and supplier relationships to uphold human rights and eliminate modern slavery risks. Our goals include:

• Increasing supplier transparency
• Expanding ethical sourcing partnerships
• Enhancing audit procedures
• Deepening engagement across the value chain

8. Approval & Endorsement

This policy is approved and endorsed by:

Michael Griffiths
Director, Premedia Marketing Production Services Pty Ltd
ABN: 61 647 912 150
Date: 1 July 2025

PromoSpark stands by our commitment to ethical sourcing and responsible business. We believe that brand excellence must be built on integrity, fairness, and the protection of human dignity across every touchpoint in our supply chain.