Modern Slavery Policy & Action Statement
"Modern slavery is an indictment on human-kind. We are committed to improving our practices to combat slavery and human trafficking."
– Guy Dawson, CEO
What is Modern Slavery?
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
Organisational structure
We are a provider of branded uniforms and merchandise in the retail sector.
We operate in Australia and engage staff and contractors both locally and internationally. We also purchase from Australian and international suppliers, many of whom are based in Asia.
We have an annual turnover between $5–$10 million.
Our supply chains
Our supply chains include Chinese manufacturers, international sea and road freight, Australian importers and wholesalers, Australian branding and decoration suppliers, and local freight providers.
We recognise that modern slavery risks are more likely in:
Offshore manufacturing (particularly in Asia)
Low-skilled labour roles (e.g. branding, packing, warehousing)
Use of migrant workers in both overseas and Australian supplier facilities
Labour hire agencies with limited transparency
Our policies on slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
We have reviewed our workplace systems, policies and procedures to assess their effectiveness in identifying and tackling modern slavery issues. These policies demonstrate our commitment to acting ethically and with integrity in all our business relationships.
We enforce effective systems and controls to help ensure slavery and human trafficking are not taking place in our supply chains.
Due diligence processes for slavery and human trafficking
As part of our initiative to identify and mitigate risk, we have put in place the following measures:
Factory tours by our CEO and sourcing agent (Christina Lee)
Screening for high-risk suppliers based on region and service
Contract clauses addressing ethical sourcing and modern slavery
Training of key staff in identifying and managing risks
Monitoring via KPIs such as training completion and issue reporting
Whistleblower protections
Supplier adherence to our values
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values, we include anti-slavery clauses in our supplier agreements and review these regularly.
Governance
Oversight of our modern slavery efforts is led by our CEO, Guy Dawson, and supported by:
Emma Fairless (Sales Team Leader)
Christina Lee (China Sourcing Agent)
This team ensures due diligence activities are aligned with our values.
Training
While we hold no formal qualifications, our CEO and leadership team have undertaken multiple webinars and industry sessions on identifying, assessing and responding to modern slavery risks. We are extending this training to all relevant staff, particularly those involved in procurement or supplier engagement.
Remediation and whistleblower protection
If we receive any allegations of modern slavery or substandard conditions:
We initiate an immediate investigation
Suspend orders if risk is not mitigated
Require the supplier to take corrective action
Disengage with any supplier that cannot meet our standards
We treat all whistleblowers confidentially and protect them from retaliation.
Our effectiveness in combating slavery and human trafficking
We track our effectiveness through:
Completion of internal reviews
Communication with suppliers on ethical standards
Number of staff trained
Number of reported incidents
LGP Modern Slavery Risk Assessment
In 2026, Payless Promotions was assessed by Local Government Procurement as having a modern slavery risk rating of: Low
This means that our business has demonstrated awareness of modern slavery and is taking active steps to mitigate risks in our operations and supply chain.
