1. Purpose

Vision Consultants is committed to conducting business ethically, responsibly, and in full compliance with the
Modern Slavery Act 2018 (Cth). This policy outlines our commitment to preventing modern slavery,
forced labour, human trafficking, debt bondage, and exploitation within our operations and supply chains across
Australia, Southeast Asia, and all international markets in which we operate.

2. Scope

This policy applies to:

• All Vision Consultants employees, contractors, counsellors, and representatives
• All Vision Global offices and partner entities
• All suppliers, service providers, subcontractors, and third-party organisations engaged by Vision Consultants

3. Our Commitment

Vision Consultants is committed to:

• Ensuring our recruitment, counselling, and education-placement activities uphold the highest ethical standards.
• Protecting students, families, and staff from exploitation or coercion.
• Conducting due diligence on suppliers and partners to identify and mitigate modern slavery risks.
• Maintaining transparent, fair, and lawful business practices.
• Ensuring our staff are trained to recognise and report modern slavery concerns.

4. Understanding Modern Slavery

Modern slavery includes situations where coercion, threats, deception, or exploitation undermine a person’s
freedom. This may include:

• Forced labour
• Human trafficking
• Debt bondage
• Child labour
• Restriction of movement or withholding of identity documents
• Unfair recruitment practices
• Exploitative working or living conditions

Vision Consultants recognises that modern slavery risks may be heightened in international recruitment markets,
particularly where vulnerable students and families are involved.

5. Risk Areas in Our Operations

Key areas where modern slavery risks may arise include:

• Education recruitment activities in Southeast Asia
• Third-party agents or sub-agents representing Vision Global
• Marketing and promotional suppliers
• Student support services provided by external partners
• Migration-related services where financial vulnerability may exist

We actively assess these areas to ensure compliance and ethical conduct.

6. Due Diligence & Supplier Controls

Vision Consultants implements the following measures:

• Conducting background checks on new suppliers and partners.
• Requiring all partners to comply with the Modern Slavery Act and Vision Consultants’ ethical standards.
• Reviewing supplier contracts to include anti-slavery clauses.
• Monitoring high-risk markets and industries.
• Ensuring no supplier charges recruitment fees to students or families.
• Ensuring no staff or partner retains passports or personal documents of students.

7. Staff Training & Awareness

All staff, including SEA-based counsellors, must:

• Complete annual training on modern slavery risks.
• Understand ethical recruitment obligations.
• Report any suspected exploitation immediately.
• Uphold Vision Consultants’ zero-tolerance stance on coercion or unethical behaviour.

8. Reporting Concerns

Vision Consultants encourages confidential reporting of any suspected modern slavery incident.
Reports may be made to:

Modern Slavery Compliance Officer
Vision Consultants Australia
Email:

compliance@visionconsultants.com.au

Phone: +61 7 0000 0000

All reports are investigated promptly, confidentially, and without retaliation.

9. Response & Remediation

If modern slavery is suspected or identified:

• Immediate protective action will be taken for affected individuals.
• The relationship with the supplier or partner may be suspended or terminated.
• A remediation plan will be implemented.
• Relevant authorities will be notified where required.

10. Continuous Improvement

Vision Consultants is committed to:

• Annual review of this policy.
• Publishing a Modern Slavery Statement where legally required.
• Strengthening supplier audits and risk assessments.
• Enhancing staff training and community awareness.

11. Policy Governance

This policy is approved by the Vision Consultants Executive Team and applies across all Vision Global and
Vision Consultants Australia operations.

Effective Date: February 2026
Review Date: February 2027