Modern Slavery Statement

This is the Modern Slavery Statement of upcover Group Holding, including Experience Insurance Services (ABN:41 657 596 506), upcover (ABN: 17 628 197 437) and upcover NZ Ltd (NZBN 9429052284724) ("upcover Group").   
‍
Upcover group is committed to preventing modern slavery, human trafficking, forced labor, and child labor in all parts of our business and supply chains. We recognise that modern slavery is a grave violation of human rights and we take a zero-tolerance approach to any form of exploitation within our operations and business relationships.

‍Our Business and Supply Chains
‍Upcover democratises access to market-leading insurance online for Australian businesses. Our supply chains include technology service providers, insurance partners, professional services firms. We recognise that certain sectors and geographic regions may present heightened risks of modern slavery, and we are committed to identifying and addressing these risks.

‍Risk Assessment and Due Diligence
‍We conduct regular risk assessments to identify potential modern slavery risks within our operations and supply chains. Our due diligence processes include:

• Screening new suppliers and partners against modern slavery risk indicators
• Conducting periodic audits of high-risk suppliers
• Requiring suppliers to confirm compliance with applicable modern slavery laws
• Monitoring and reviewing supplier compliance on an ongoing basis

Policies and Governance
‍Our Anti-Modern Slavery Policy sets clear expectations for all employees, contractors, and business partners. This is supported by our Code of Conduct and Whistleblowing Policy. Our Board of Directors has ultimate responsibility for our modern slavery response, with day-to-day oversight delegated to our Chief Compliance Officer.
‍Training and Awareness
‍We provide regular training to employees who manage supplier relationships or are involved in recruitment and hiring. This training covers:

• Identifying signs of modern slavery
• Understanding high-risk indicators
• Reporting procedures for suspected cases
• Our policies and expectations

Reporting Mechanisms
We maintain confidential reporting channels for anyone to raise concerns about potential modern slavery in our operations or supply chains. We guarantee non-retaliation for good-faith reporting and investigate all credible allegations promptly and thoroughly.
Performance Indicators
We measure the effectiveness of our actions through:

• Percentage of relevant staff trained on modern slavery awareness
• Number of supplier assessments conducted
• Time to investigate and resolve reported concerns
• Supplier compliance rates with our anti-slavery requirements

Continuous Improvement
‍We recognise that eliminating modern slavery requires ongoing vigilance and collective action. We are committed to:

• Regularly reviewing and strengthening our approach
• Collaborating with industry peers and civil society organizations
• Transparently reporting on our progress and challenges
• Supporting initiatives that advance human rights in global supply chains

This statement has been approved by our Board of Directors and reflects our commitment to maintaining the highest standards of ethical business conduct.
‍
Skye Theodorou
Director and CEO
EIS
Co-Founder & CEO
upcover Group Holding

‍