Modern Slavery Satatement

Purpose and commitment

Modern slavery and human trafficking are serious crimes and a violation of fundamental human rights. Vault Systems Pty Ltd (“Vault Cloud”) has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or supply chain.

Our business and supply chains

Vault Cloud provides hyperscale cloud services and specialist IT and security consultancy. We operate primarily in Australia and work with partners and suppliers in Australia, the United Kingdom and the United States.

Our supply chain typically includes:

● Cloud and data centre services, connectivity and managed service partners

● Technology vendors (hardware, software, licensing and support)

● Professional services suppliers (consultancy, recruitment and subcontractors)

● Corporate services (legal, finance, travel, facilities and utilities)

Governance and responsibility

Overall responsibility for this statement and for our approach to modern slavery sits with the Board. Day-to-day ownership is delegated to senior management who ensure that appropriate policies, supplier controls, and reporting arrangements are in place and reviewed periodically.

Policies and controls

Vault Cloud maintains an Anti-Slavery Policy that sets minimum standards for identifying, preventing and responding to modern slavery risks. Supporting controls include:

● A Code of Conduct and ethical standards expected of employees and suppliers

● Whistleblowing and reporting arrangements enabling concerns to be raised confidentially

● Supplier onboarding and due diligence checks proportionate to risk

● Contractual terms requiring compliance with modern slavery legislation

Risk assessment and due diligence

We apply a proportionate, risk-based approach to assessing suppliers, considering the nature of goods and services provided, labour intensity, geographic risk indicators, and adverse media or enforcement actions.

Training and awareness

We provide awareness guidance to staff involved in procurement and supplier management to help identify potential indicators of modern slavery and to ensure concerns are escalated appropriately.

Effectiveness and continuous improvement

We continue to strengthen supplier engagement and improve visibility across our supply chain, with periodic management review of risk controls and due diligence effectiveness.

Approval

This statement is made pursuant to the Modern Slavery Act 2018 (Cth) and constitutes Vault Cloud’s modern slavery statement for the financial year 1 July 2025 to 30 June October 2026.