May 2023

Statement of the Modern Slavery Act

This statement is published by Jungal Pty Ltd pursuant to section 54 (1) of the Modern Slavery Act 2015 (the “Act”) and constitutes the slavery and human trafficking statement for the financial year 1 January 2022 to 31 December 2022 for Jungal Pty Ltd and each of its subsidiaries further listed in the “Organisational structure & supply chains” section below (together the “Jungal Pty Ltd”). The Jungal Pty Ltd takes a zero tolerance approach to slavery and human trafficking in our business operations and supply chains.


 Our approach

Across the Jungal Pty Ltd we strive to work to the highest professional standards and comply with all laws, regulations and rules relevant to our business.


Our people and legal teams work in conjunction with our procurement function to help ensure that the aims and provisions of the Act are complied with and to manage any concerns or breaches. Our Modern Slavery Code of Conduct sets out the standard of conduct for customers, contractors, and vendors working with us. It is publicly available on our website and we seek to impose contractual obligations on vendors to comply with this as part of contractual negotiations for supply contracts where possible.


Our recruitment and employment procedures include appropriate pre-employment screening of all Jungal Pty Ltd employees, such as right to work checks and reference checks. New employees also receive an induction and new hire training which explains Jungal Pty Ltd policies and confirms that employees are able to contact our Administration Team (the Crew) or our whistleblower email account confidentially on any matter of concern, throughout their employment.

We expect all Jungal Pty Ltd employees to conduct business with honesty and integrity and we have a zero tolerance approach to bribery and corruption, as set out in our Anti-Bribery & Corruption Policy.


In our Code of Ethics we describe our commitment to conducting our business with the highest ethical standards. Trust, transparency, and integrity are values that are important to the entire Jungal Pty Ltd, which means we expect the people who work for us, and those we do business with, to always act with integrity, build trust and promote transparency, and make decisions that reflect strong ethics. We avoid doing business with businesses that do cause or create harm, do not align with our ethical standards, or do not share the same values and core beliefs as us. These “bad-fit” businesses may harm Jungal’s reputation and undermine the trustworthiness of our platform.

Jungal Pty Ltd policies

Our Jungal Pty Ltd policies work to identify and prevent any slavery and human trafficking within our operations. We work to maintain high professional and ethical standards and ensure our employees know their role in maintaining these. All Jungal Pty Ltd employees are provided with a written contract of employment, including Jungal’s Code of Ethics, and are governed by corporate policies.

Due diligence/Risk assessment

We seek to work with customers, contractors, and vendors who match and complement our ethical standards and organisational values.

To identify sectors and categories with high modern slavery risks, we have used the following indicators that are generally known to increase risk likelihood:

  • Reliance on low-skill workforce.
  • Reliance on migrant workforce.
  • Presence of children.
  • Hazardous or undesirable work.
  • Based in a country that experiences high levels of corruption, weak governance, and poor enforcement of human rights.

As Jungal is an online-based business, our main vendors comprise providers of online-based services to facilitate our platform, and general advisory services from reputable businesses. Based on these factors, we consider the risk of modern slavery in our supply chain to be low. Our identification and verification process of gigstars examines the indivuals and rigth to work in their region with expert independent certification. 

We continue to:

  • Undertake due diligence when short-listing our vendors, gigstars and contractors.
  • Review on a regular basis the vendors, gigstars and contractors we use.
  • Enter into business relationships with vendors that reflect our organisational values.
  • Seek to ensure that any vendor or contractor has an ethical treatment clause in the vendor contract they provide us especially where we deem them to be medium to high risk based on their geographical location or otherwise. This is to ensure that the work environment and conditions they provide to their employees meet standards under our Modern Slavery Code of Conduct.

If a vendor or contractor fails to live up to our expectations or is unwilling to make any changes, we may end our engagement with them.

Further steps

We continue to strive to improve the measures we take across the Jungal Pty Ltd to ensure that we mitigate the risk of modern slavery within our supply chains.

  • We have developed modern slavery specific training for all employees in the Jungal Pty Ltd involved in the recruitment of staff and procurement of vendors to support them in identifying risk factors, understanding the implications, and assisting with implementing the requirements of the Act effectively.
  • We continue to seek contractual rights to request compliance-related information and the right to audit vendors at our discretion, as well as seeking improvements in ensuring that risk areas are documented, monitored and taken into consideration when contracting with vendors.