Modern Slavery & Human Trafficking Policy

Status: v1.0
Tier: Tier 1 – Core Corporate & Platform Policy
Owner: Governance and Compliance Function
Approval Authority: Board of Directors
Effective Date: 5 January 2026
Next Review: 12 months from approval

1. Purpose

This policy sets out Global Talent Pathway’s commitment to preventing modern slavery, human trafficking, forced labour, debt bondage, and other forms of labour exploitation in connection with its operations, platforms, supply chains, and workforce-related activities.

This policy exists to:

  • protect individuals from exploitation,

  • manage legal, operational, and reputational risk, and

  • meet expectations of government, enterprise clients, and regulators.

2. Scope

This policy applies to:

  • Global Talent Pathway’s workforce and recruitment operations,

  • digital platforms and portals,

  • candidates, workers, and jobseekers engaging with the platform,

  • employers, recruiters, labour intermediaries, and agents,

  • suppliers, contractors, and service providers, and

  • staff, officers, and representatives of Global Talent Pathway.

This policy applies across all jurisdictions in which Global Talent Pathway operates.

3. Policy Statement

Global Talent Pathway has zero tolerance for modern slavery and human trafficking in any form.

We are committed to taking reasonable, risk-based, and proportionate steps to identify, prevent, mitigate, and respond to risks of modern slavery and labour exploitation associated with our activities and relationships.

4. Prohibited Practices

The following practices are strictly prohibited in connection with Global Talent Pathway activities:

  • forced labour or compulsory labour,

  • human trafficking or trafficking-like conduct,

  • debt bondage,

  • retention of identity documents (including passports) as a condition of work,

  • threats, coercion, intimidation, or abuse of power,

  • deception or misrepresentation relating to work, wages, conditions, or location,

  • charging workers recruitment or placement fees, directly or indirectly,

  • any arrangement that restricts a worker’s freedom to leave employment.

5. Recruitment Fees

Global Talent Pathway does not permit workers or candidates to be charged recruitment, placement, or related fees as a condition of accessing employment opportunities facilitated through our platform or services.

This includes fees charged by:

  • employers,

  • recruiters,

  • labour hire firms,

  • agents or intermediaries,

  • third parties acting on behalf of any of the above.

6. Risk Management Approach

Global Talent Pathway adopts a risk-based approach to modern slavery risk management, taking into account factors such as:

  • geographic location,

  • industry and role type,

  • labour supply arrangements,

  • use of intermediaries,

  • vulnerability of worker populations.

Risk controls may include:

  • due diligence on employers and suppliers,

  • contractual prohibitions and representations,

  • monitoring and review,

  • complaint and disclosure mechanisms.

7. Responsibilities

Global Talent Pathway

  • Maintain and enforce this policy.

  • Implement reasonable controls proportionate to identified risks.

  • Provide reporting mechanisms for concerns.

  • Take appropriate action where risks or breaches are identified.

Employers, Recruiters and Suppliers

  • Comply with this policy and applicable laws.

  • Not engage in prohibited practices.

  • Cooperate with due diligence, monitoring, and investigations.

Staff and Representatives

  • Act consistently with this policy.

  • Report suspected or actual breaches promptly.

8. Reporting and Response

Concerns or suspected breaches of this policy must be reported through Global Talent Pathway’s Complaints & Disclosures Framework.

Reports may be made confidentially or anonymously.

Global Talent Pathway will:

  • assess reports promptly,

  • take proportionate action where warranted, and

  • escalate matters to authorities where required by law.

9. No Guarantee

Global Talent Pathway does not guarantee the absence of modern slavery risks. This policy reflects a commitment to reasonable steps, not absolute outcomes.

10. Review

This policy will be reviewed annually and updated as required.