Axiom Data's commitment to identifying and addressing the risk of modern slavery in its operations and supply chain, and the assessment it has made of that risk.
Legislation and standards this policy gives effect to
Modern slavery includes forced labour, debt bondage, deceptive recruiting, servitude, human trafficking and the worst forms of child labour. Axiom Data will not engage in, tolerate or knowingly benefit from any of these practices in its own operations or in its supply chain, and it expects the same of its partners and suppliers. Although Axiom Data is below the revenue threshold for mandatory reporting under the Modern Slavery Act 2018, we assess our risks, act on them, and will report voluntarily or to clients on request.
This policy applies to Ontology Analytics Pty Ltd, trading as Axiom Data (Axiom Data) and to every director, employee, labour-hire worker, contractor and agent engaged by Axiom Data, whether working at Axiom Data's premises, remotely, or on placement at a client site. Where a worker is placed with a client, this policy applies alongside the client's own policies; where the two differ, the worker follows the stricter requirement and raises the difference with Axiom Data.
Axiom Data supplies ICT professionals to Australian Government agencies and builds software. Our workforce is professional, Australian-resident, directly employed or engaged under written agreements at or above award rates, and free to leave. Our supply chain consists mainly of: Australian sourcing partners who refer candidates; cloud, software and telecommunications providers; professional services (accounting, legal, insurance); and office equipment.
| Area | Risk | Rating | Why |
|---|---|---|---|
| Our own workers | Forced or underpaid labour, debt bondage, passport retention. | Low | Professional ICT roles; right to work verified; award-compliant pay; written contracts; no recruitment fees charged to workers; no accommodation or travel debts; workers hold their own documents. |
| Sourcing partners (labour-hire and recruitment) | Candidates recruited deceptively or charged fees; partner workers underpaid. | Low to medium | Partners are Australian ICT recruiters; candidates are placed only after Axiom Data verifies identity, right to work and consent; candidates are never charged. Partners confirm compliance with this policy in their agreements. |
| Offshore services (software, cloud, outsourced work) | Labour exploitation in offshore delivery. | Low | Axiom Data does not offshore its labour-hire or Commonwealth delivery work; cloud providers used are major vendors with published modern slavery statements. |
| Electronics and office goods | Forced labour in manufacturing supply chains. | Medium (inherent), low (exposure) | Small volumes purchased from mainstream Australian retailers; brand selection favours vendors with published statements. |
The Director and anyone involved in sourcing or procurement is briefed on modern slavery indicators as part of induction and at the annual policy review. Partners receive this policy with their agreement.
At the annual review the Director records: the number of suppliers and partners assessed; any concerns raised and their outcome; any change in the supply chain; and whether the controls above were applied in every placement. The risk assessment is updated accordingly.
This policy is owned by the Director and is reviewed at least annually, and sooner if legislation, a client requirement or an incident shows the need. The current version, effective date and next review date are recorded in the policy register on the Employee Resources page.
Modern Slavery Policy and Risk Assessment · POL-10 v1.0 · Ontology Analytics Pty Ltd, trading as Axiom Data (ABN 36 653 416 856) · Approved by Atif Mahmood, Director · Effective 12 October 2026