Effective Date: 1 January 2025
Version: 3.0 — Ultra-Final (Djenie Edition)

1. INTRODUCTION

This Modern Slavery Statement outlines the actions taken by In Delay There Lies No Plenty Pty Ltd ACN 162 881 138 ATF Future Thinking Family Trust t/a Djenie ABN 98 399 797 036 (“Djenie”) to identify, assess, prevent, and mitigate modern slavery risks in our operations and supply chains.
Although not currently mandated under the Australian Modern Slavery Act 2018 (Cth), Djenie voluntarily publishes this Statement to demonstrate strong ethical governance and meet global ESG expectations.
Aligned frameworks include:

  • Australian Modern Slavery Act 2018 (Cth)
  • UN Guiding Principles on Business and Human Rights (UNGP)
  • ILO Conventions
  • OECD Due Diligence Guidance
  • Global supply-chain transparency standards

2. ORGANISATIONAL STRUCTURE, OPERATIONS & SERVICES

Djenie is an Australian technology organisation providing:

  • membership-management systems (including SMS v2)
  • custom software development
  • cloud hosting and platform maintenance
  • consulting and digital-transformation services
  • data protection, privacy, and security operations

Operations are primarily Australia-based, supported by international cloud providers and selectively engaged overseas partners.

3. SUPPLY CHAIN OVERVIEW

Djenie’s supply chains include:

  • cloud hosting, infrastructure vendors, and SaaS platforms
  • engineering, software development, cybersecurity, and compliance partners
  • IT hardware providers
  • professional services (legal, accounting, advisory)
  • international support vendors

Risk levels differ based on geography, labour protections, and transparency within upstream layers.

4. MODERN SLAVERY RISK ASSESSMENT

Key areas of potential risk:

  • electronics and hardware supply chains involving high-risk labour markets
  • offshore development where employment protections vary
  • indirect subcontracting in multi-layer supply chains
  • logistics and global electronic components
  • outsourced labour markets with reduced transparency

5. ACTIONS TAKEN TO DATE

Djenie maintains:

  • supplier due-diligence checks including ESG and labour-standards screening
  • contractual clauses requiring ethical labour compliance
  • preference for suppliers with established modern slavery frameworks
  • internal anti-bribery, ethical procurement, and Code of Conduct policies
  • training for procurement and senior leadership on modern slavery indicators
  • annual assessments of emerging risk jurisdictions

6. ENHANCED DUE DILIGENCE REQUIREMENTS

High-risk suppliers must:

  • complete an ESG/modern slavery questionnaire
  • provide evidence of compliance programs
  • submit corrective action plans (CAPs) where gaps exist
  • participate in third-party labour-standards audits where applicable

7. SUPPLIER TIERING & RISK MAPPING

  • Djenie applies a three-tier model:
  • Tier 1 – Direct strategic suppliers (cloud, hosting, critical SaaS)
  • Tier 2 – Professional services and engineering partners
  • Tier 3 – Hardware suppliers, logistics, high-risk-jurisdiction vendors

High-risk suppliers undergo annual reassessment.

8. WORKER GRIEVANCE & REMEDIATION FRAMEWORK

Where labour concerns arise, Djenie will:

  • engage suppliers to investigate concerns
  • suspend or terminate the supplier if remediation fails
  • support affected worker remediation where feasible
  • notify relevant authorities if required
  • document findings for governance and future reviews

9. KPIs TO MEASURE EFFECTIVENESS

  • percentage of suppliers completing modern slavery screening
  • number and status of corrective actions raised
  • training completion rates for procurement and leadership
  • reported incidents and remediation outcomes
  • reassessment outcomes for high-risk suppliers

10. CONSULTATION, GOVERNANCE & ACCOUNTABILITY

Oversight rests with:

  • Chief Executive Officer (Accountable Executive)
  • Compliance & Data Protection Lead
  • Security & Governance Committee

Cross-business consultation involves engineering, procurement, finance, and operations.

11. FUTURE COMMITMENTS

Djenie commits to:

  • publishing a Supplier Code of Conduct aligned with UNGP and ILO standards
  • establishing supplier engagement and awareness programs
  • expanding independent audits for high-risk categories
  • enhanced onboarding requirements and attestations
  • strengthening transparency reporting across all controlled entities
  • implementing an escalation matrix for supplier investigations

12. APPROVAL

This Statement has been approved by the Chief Executive Officer of Djenie.

Peter Riley Djenie
Chief Executive Officer
Djenie
1 January 2025

VERSION CONTROL & GOVERNANCE

Version: 3.0 — Djenie Edition
Change Summary: Full rewrite from Cushi version; supplier-tiering, grievance protocols, KPIs, and risk controls aligned to Djenie’s operational structure.
Next Review: 12 months or earlier as required.