Modern Slavery Statement
1. Introduction
Empulse Group Pty Ltd (EMPULSE®) is committed to conducting business responsibly, ethically, and in full alignment with the Modern Slavery Act 2018 (Cth). We recognise that modern slavery, forced labour, debt bondage, human trafficking, and child labour remain significant global risks. EMPULSE® takes a proactive approach to ensuring our operations and supply chain remain free from any form of exploitation.
This policy outlines the measures we take to identify, assess, mitigate, and remediate modern slavery risks across all EMPULSE® activities. It applies to all employees, contractors, suppliers, manufacturers, agents, and business partners.
2. Scope
This policy applies to:
- All EMPULSE® employees, directors, contractors, and consultants
- All suppliers, manufacturers, freight partners, and subcontractors
- All custom-made and branded apparel products sold or distributed by EMPULSE®
- All global and domestic supply chain partners engaged to support EMPULSE® operations
3. Our Commitment to Ethical and Responsible Sourcing
EMPULSE® is committed to:
- Maintaining a transparent and ethically managed supply chain
- Preventing modern slavery in all forms
- Conducting regular due diligence on all suppliers
- Prioritising partnerships with accredited and ethical manufacturers
- Educating internal teams on modern slavery risks and compliance
- Ensuring continuous monitoring, improvement, and corrective action where required
We maintain zero tolerance for modern slavery or labour exploitation within our operations or supply chain.
4. Our Products & Supply Chain Overview
EMPULSE® engages in the sourcing and distribution of:
- Custom apparel (sportswear, uniforms, streetwear, promotional merchandise)
- Branded apparel (Nike, Adidas, Champion, Under Armour)
- Eco-friendly and made-to-order EMPULSE® apparel lines
Our supply chain includes:
- Fabric producers and mills
- Responsible garment manufacturing partners
- Print and embroidery service providers
- Logistics, warehousing, and distribution partners
5. Due Diligence Standards
EMPULSE® requires that all suppliers:
- Adhere strictly to the Modern Slavery Act 2018
- Maintain transparent employment documentation
- Guarantee voluntary labour with no coercion, withholding of identification, or recruitment fees
- Provide safe, fair, and lawful working conditions
- Respect freedom of movement and association
- Uphold fair compensation practices
- Provide access to grievance and whistleblowing mechanisms
- Submit to EMPULSE®’s scheduled and unscheduled audits
- Promptly address any non-compliance issues
Failure to maintain these standards may result in suspension or termination of the supplier relationship.
6. Verification: Custom Apparel Partners
Our preferred custom apparel partner is AS Colour, a supplier known for high standards in ethical manufacturing. EMPULSE® reviews the following AS Colour compliance documents (available publicly):
- Ethical Sourcing Policy
- Supplier Code of Conduct
- Modern Slavery Statement
- Transparency Reports
- Factory Lists & Audit Outcomes
Where EMPULSE® uses alternative custom manufacturers, these partners must:
- Sign EMPULSE®’s Supplier Code of Conduct
- Provide proof of social compliance audits (BSCI, SEDEX, WRAP, ISO standards)
- Demonstrate transparent sourcing and safe labour conditions
- Provide evidence of ongoing ethical and sustainability initiatives
EMPULSE® explicitly prohibits sourcing from, or engaging with, any supplier, subcontractor, distributor, or agent operating in the Xinjiang Uyghur Autonomous Region (XUAR) of China, a region identified internationally for significant risks of forced labour, state-imposed labour programs, and human rights violations.
EMPULSE® does not procure materials, textiles, components, cotton, labour, or finished goods linked in any way to this region. We require suppliers to provide full transparency of their supply chain and confirm that no part of their production—including raw materials—originates from Xinjiang or from any entity associated with forced labour risks.
Suppliers unable to demonstrate this level of traceability will not be approved or will be immediately removed from our supply chain.
7. Verification: Branded Apparel Partners
For globally recognised brands we distribute—including Nike, Adidas, Champion, and Under Armour—EMPULSE® relies on:
- Human Rights Policies
- Supplier Standards of Conduct
- Modern Slavery Statements
- Global Transparency Index Submissions
- Public reporting on factory conditions
- Published sustainability and labour compliance frameworks
EMPULSE® only partners with authorised distributors and does not source branded products through unverified channels.
The above mentioned brands are global leaders in Corporate Social responsibility and each brand is soley responsible for compliance with the above mentioned policies.
8. Risk Assessment & Management
EMPULSE® assesses risk across:
- Overseas apparel manufacturing jurisdictions
- Regions with known vulnerability to forced labour
- Third-party embellishment and printing operations
- Material supply chains (e.g., cotton, synthetic fibres, dyes)
- High-volume production environments
Indicators of risk include:
Lack of supply chain visibility
- Disproportionately low cost of goods
- Subcontracting without disclosure
- Excessive overtime or unsafe conditions
- Document withholding or worker recruitment fees
Where risk is identified, EMPULSE® conducts additional due diligence, requests corrective actions, and may initiate third-party audits. Suppliers that are deemed at risk, as not approved and alternative sources of supply are procured.
9. Remediation Process
If potential or confirmed modern slavery is discovered:
- EMPULSE® notifies the supplier immediately.
- A corrective action plan is required and monitored.
- Failure to rectify non-compliance leads to contract termination.
- EMPULSE® supports fair and lawful remediation for affected workers where possible.
10. Employee Training & Awareness
EMPULSE® ensures employees are trained to:
- Recognise signs of modern slavery
- Understand responsible procurement practices
- Carry out supplier assessments
- Respond to risks appropriately
- Promote ethical sourcing internally and externally
Training is provided annually or when legislation changes.
11. Reporting, Whistleblowing & Transparency
EMPULSE® encourages employees, suppliers, and stakeholders to raise concerns regarding potential modern slavery risks.
We guarantee:
- Confidential reporting pathways
- No retaliation for good-faith reporting
- Prompt investigation of every concern raised
12. Monitoring & Continuous Improvement
EMPULSE® is committed to ongoing improvement through:
- Annual policy reviews
- Updated risk assessments
- Enhanced supplier onboarding
- Increased transparency measures
- Adoption of new global best-practice standards
13. Annual Review
This policy will be reviewed annually by the EMPULSE® Board of Directors to ensure ongoing compliance with evolving laws, global standards, and industry expectations.
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