1. Opening Statement: Legal Compliance & Modern Slavery Awareness

Supalai Australia Holdings Pty Ltd (SAH) recognizes that modern slavery is a critical global human rights challenge and acknowledges that the property and construction sector carries inherent risks across complex, multi-tiered supply chains. In compliance with section 13 of the Australian Modern Slavery Act 2018 (Cth), SAH has submitted its FY25 Modern Slavery Statement as a reporting entity. Approved by the Board of Directors, this report outlines our ongoing commitment to identifying, assessing, and mitigating modern slavery risks across our Australian operations and supply chains.

2. Operating Model: Non-Operating Investor & Partner-Led Risk Management

Supalai operates in Australia primarily as a non-operating investor, holding interests in residential property projects through joint venture (JV) and joint operation (JO) structures rather than directly managing day-to-day construction or procurement.

  • JV/JO-Partner-Led Risk Mitigation: Approximately 90% of Supalai’s Australian asset value is invested alongside leading Australian property developers—such as Stockland, Mirvac, and Peet—who are themselves reporting entities under the Modern Slavery Act 2018 (Cth).
  • Established Due Diligence & Controls: Operational delivery, on-site labor standards, and supplier engagement are managed directly through our partners' established risk frameworks. These include rigorous supplier codes of conduct, worker site inductions, third-party supply chain audits, and contractor assurance reviews.
3. Future Commitments & Continuous Improvement

Supalai remains dedicated to progressively enhancing its modern slavery governance and risk management program. Our key commitments for the upcoming reporting period include:

  • Formalizing Partner Engagement: Incorporating modern slavery as a standing quarterly agenda item to capture any audit outcomes and incident reporting.
  • Expanding Supplier Visibility: Initiating direct modern slavery risk engagement with delivery partners who are not subject to mandatory reporting under the Act.
  • Internal Capability Building: Delivering tailored modern slavery awareness and understanding to Supalai personnel related to the Australian investment.