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EB Pearls Modern Slavery Statement

At EB Pearls, we are committed to upholding the dignity and rights of every person involved in our operations and supply chain. We have established a formal process to identify, assess, and address risks of modern slavery—ensuring our practices are ethical, transparent, and aligned with international human rights standards. This statement is made in accordance with the Modern Slavery Act 2018 (Cth).

 

About EB Pearls

EB Pearls is a digital consultancy headquartered in Sydney, with a delivery centre in Kathmandu, Nepal. We design and build digital products for startups, scale-ups, and enterprise clients across Australia. Our team of over 200 employees spans product strategy, UX/UI, engineering, and client services.

 

Our Modern Slavery Compliance Framework

We have implemented a structured, ongoing compliance framework to ensure modern slavery risks are proactively managed.

1. Governance & Accountability

  • Executive oversight provided by our Chief Operating Officer

  • Operational responsibility held by our People Operations & Procurement Leads

  • Annual compliance reviews are reported to the Executive Leadership Team

 

2. Risk Identification & Assessment

We regularly assess risk across three key domains:

  • Operations Risk: Assessed as low; all staff are directly employed, paid fairly, and covered by EB Pearls’ workplace policies.

  • Supply Chain Risk: Moderate risk areas include electronics hardware, cleaning services, and third-party fit-out or construction contractors.

  • Geographical Risk: We apply enhanced diligence to Nepal-based vendors and global suppliers in higher-risk regions.

 

3. Due Diligence Process

We conduct supplier onboarding and periodic reviews that include:

  • Screening for modern slavery and human rights breaches

  • Requirement to comply with our Supplier Code of Conduct

  • Ethical sourcing and labour standards clauses in contracts

  • Escalation protocol for non-compliance or concerns

 

4. Employee Awareness & Training

  • Modern slavery awareness integrated into manager onboarding and procurement roles

  • Annual training for relevant staff (People Ops, Finance, Procurement)

  • Internal comms on ethical sourcing expectations and reporting pathways

 

5. Remediation & Grievance Pathways

  • We maintain a formal grievance process available to all employees and suppliers

  • Any suspected modern slavery issues are investigated by our People Ops team and escalated to ELT as needed

  • Remedial action plans are created where issues are identified

 

Monitoring & Continuous Improvement

EB Pearls tracks progress through quarterly internal reviews and an annual compliance health check.
Our priorities for FY25 include:

  • Expanding risk mapping to Tier 2 and 3 suppliers

  • Strengthening supplier self-assessment requirements

  • Publishing a modern slavery awareness guide for staff

  • Establishing an anonymous grievance channel across all offices

 

Contact Us

If you have questions or would like further information about our approach to modern slavery:

People & Culture Team
- hr@ebpearls.com.au
- www.ebpearls.com.au