Modern Slavery Policy

We Are SAM | Sydney, New South Wales, Australia

Effective date: 30 October 2026
Review frequency: Annually

1. Our Commitment

We Are SAM is committed to conducting business ethically, responsibly and with respect for human rights.

We recognise that modern slavery is a serious violation of fundamental human rights and that businesses of all sizes have a responsibility to identify, prevent and address the risks of modern slavery within their operations and supply chains.

We have zero tolerance for modern slavery, human trafficking, forced labour, debt bondage, servitude, child exploitation and other forms of coercive or exploitative labour practices.

We are committed to taking reasonable and proportionate steps to minimise these risks and to working with suppliers, contractors and business partners who share our commitment to fair, safe and ethical working conditions.

2. About We Are SAM

We Are SAM is a Sydney-based automotive events, media production and content agency specialising in vehicle launches, media events, photography, video production, creative content and related services.

Our business works with clients, independent contractors, creative professionals, production teams, venues and third-party service providers to deliver projects across Australia.

We recognise that our business activities involve a range of suppliers and contractors, including providers of event staffing, hospitality, transport, accommodation, production equipment, photography, video services and promotional materials.

While we consider our direct operations to present a relatively limited exposure to modern slavery risks, we acknowledge that risks may exist within our broader supply chains, including through subcontracting and the overseas manufacture of goods and equipment.

3. Our Approach to Modern Slavery

We Are SAM supports the objectives of the Modern Slavery Act 2018 (Cth), the Modern Slavery Act 2018 (NSW) and internationally recognised principles concerning human rights and fair employment practices.

Our approach is informed by Australian Government guidance and the NSW Anti-slavery Commissioner's recommendations for identifying and managing modern slavery risks.

We are committed to:

  • Conducting business with integrity and respect for human rights.

  • Complying with applicable Australian workplace, employment and human rights laws.

  • Engaging suppliers and contractors who demonstrate responsible employment practices.

  • Identifying and assessing potential modern slavery risks where reasonably practicable.

  • Taking appropriate action when credible concerns about exploitative labour practices are identified.

  • Encouraging transparency and accountability throughout our business relationships.

  • Reviewing and improving our approach as our business and supply chains evolve.

4. Employment and Working Conditions

We Are SAM is committed to fair, safe and lawful working arrangements for employees, freelancers, contractors and other personnel engaged in our operations.

We expect all work undertaken on our behalf to be voluntary and free from coercion, threats, intimidation or exploitation.

Our employment and engagement practices are guided by the following principles:

  • All workers must be legally entitled to undertake their work.

  • Workers must receive lawful remuneration and applicable employment entitlements.

  • Workers must not be required to surrender passports, identification documents or personal property as a condition of employment.

  • Workers must be free from forced labour, debt bondage, human trafficking and other exploitative practices.

  • Working arrangements must comply with applicable workplace health and safety requirements.

  • Workers must be treated with dignity and respect, without unlawful discrimination, harassment or intimidation.

We expect contractors and suppliers engaged by We Are SAM to uphold equivalent standards within their own operations.

5. Supply Chain Responsibility

We Are SAM recognises that modern slavery risks can arise at different stages of a supply chain, including within businesses that provide goods or services indirectly.

We seek to work with reputable suppliers and contractors whose employment practices align with our ethical standards.

Our approach to supplier engagement includes, where appropriate:

  • Considering a supplier's reputation, business practices and compliance with applicable laws.

  • Assessing potential labour exploitation risks when selecting new suppliers, particularly in higher-risk industries.

  • Seeking reasonable assurances from suppliers concerning lawful employment and working conditions.

  • Encouraging suppliers to maintain responsible practices within their own subcontracting arrangements.

  • Addressing identified concerns through supplier engagement, corrective action or reconsideration of the business relationship.

We recognise that some sectors, including event labour hire, cleaning, hospitality, transport, textiles, merchandise manufacturing and equipment supply, may present heightened risks.

Where these services or products form part of a project, we will seek to apply an appropriate level of scrutiny based on the nature, location and circumstances of the procurement.

6. Identifying and Managing Risks

We Are SAM adopts a practical, risk-based approach to identifying and managing potential modern slavery risks.

Our assessment may consider:

  • The industry or sector in which a supplier operates.

  • The geographic location of goods production or service delivery.

  • The use of subcontractors, temporary workers or labour hire arrangements.

  • The nature of the products or services being purchased.

  • The transparency of a supplier's employment and labour practices.

  • Any credible allegations, adverse findings or other indicators of worker exploitation.

Where risks are identified, we will consider appropriate measures to investigate, mitigate and address those risks, taking into account the severity of the potential harm and our ability to influence the relevant supplier or business relationship.

We recognise that meaningful risk management involves ongoing engagement and improvement, rather than relying solely on declarations or contractual assurances.

7. Reporting Concerns

We encourage employees, contractors, suppliers and other stakeholders to raise any genuine concerns about suspected modern slavery, human trafficking or exploitative labour practices connected with our business activities.

Concerns can be raised directly with We Are SAM management through the contact channels available on our website:

www.wearesam.com.au

Reports will be treated seriously, discreetly and sensitively, with information shared only where reasonably necessary to assess and respond to the concern or as required by law.

We do not tolerate retaliation against any person who raises a genuine concern in good faith.

Where there is an immediate threat to someone's safety, the matter should be reported to emergency services. Suspected criminal conduct may also be referred to the appropriate authorities.

8. Responding to Identified Risks

If We Are SAM becomes aware of a credible modern slavery concern within its operations or supply chains, we will assess the circumstances and take appropriate action.

Depending on the nature and seriousness of the concern, this may include:

  • Seeking additional information from the relevant supplier or contractor.

  • Investigating the circumstances and assessing potential harm to affected individuals.

  • Consulting suitably qualified advisers or relevant authorities where appropriate.

  • Working with suppliers to implement corrective measures and prevent further harm.

  • Supporting access to appropriate assistance or remedy for affected individuals, where we have caused or contributed to harm.

  • Suspending or terminating a supplier relationship where serious concerns cannot be adequately addressed.

Our response will prioritise the safety, wellbeing and rights of potentially affected individuals.

We recognise that immediately terminating a supplier relationship may not always be the most effective response where doing so could increase harm to vulnerable workers.

9. Responsibility and Continuous Improvement

Responsibility for implementing this policy rests with We Are SAM management.

We are committed to periodically reviewing our approach to modern slavery risk management and making improvements appropriate to the size, nature and activities of our business.

This may include reviewing supplier arrangements, increasing awareness among relevant personnel, updating procurement practices and responding to developments in legislation or government guidance.

We recognise that identifying and preventing modern slavery is an ongoing responsibility requiring vigilance, transparency and continuous improvement.

10. Policy Review

This policy will be reviewed at least annually, or earlier where significant changes occur in our business operations, supply chains, relevant legislation or government guidance.

We Are SAM is committed to maintaining responsible business practices and promoting ethical conduct in all aspects of our work.

We Are SAM
Sydney, New South Wales, Australia
www.wearesam.com.au