Modern Slavery Statement

This is a voluntary statement under the Modern Slavery Act 2018 (Cth). RewardCo is below the revenue threshold that makes a statement mandatory, but we have chosen to report because our clients ask about their supply chains, and we are part of them. Our consolidated revenue is below A$100 million, and we will give the Minister written notice that we are reporting voluntarily, as section 12 of the Act provides.

Modern slavery means serious exploitation, such as forced labour, debt bondage, human trafficking, servitude, deceptive recruiting and the worst forms of child labour. It does not cover substandard working conditions or underpayment on their own, though those can be warning signs.

This statement follows the mandatory criteria in section 16 of the Act:

The reporting entity is Rewardco International Pty Ltd (ABN 84 169 704 938), an Australian proprietary company limited by shares. We trade as RewardCo.

Our office and registered office is at 1/6 Hassall Street, Parramatta NSW 2150.

Rewardco International Pty Ltd does not own or control any other entities, in Australia or overseas.

We have no employees. Our directors and 4 regular contractors do our work.

RewardCo provides a software platform for recognition, incentive and loyalty programs. Organisations use it to reward their staff, dealers, channel partners and customers with points, gift cards, cashback and other rewards.

Clients can run their program themselves on the platform, or have RewardCo run it for them. When we run a program, we check or approve claims, pay out rewards, help participants and send a monthly report. Agencies can also offer RewardCo programs to their own clients.

Our work is office-based and online: software development, hosting and support of the platform, program set-up and management, sales and administration. Our team works from Parramatta and from the Philippines.

We buy goods and services in these main categories:

• Cloud hosting and software services. Hosting for the platform, email delivery, development tools and business software. Our main providers are DigitalOcean, Hetzner, Google and Microsoft.
• Gift card and digital reward providers. GiftPay supplies gift cards in Australia, New Zealand, Singapore, the United Kingdom, the United States and Canada. Gifted supplies rewards in the Philippines, including GCash. These providers in turn source cards from retailers and card issuers.
• Payment providers. Airwallex pays cashback and rewards to participants' local bank accounts.
• Physical rewards. We do not supply physical merchandise ourselves. Physical items are rare in our programs and are supplied through the client, not RewardCo. Our own rewards are digital: gift cards, points and payouts.
• Contractors. Software development, design, testing and support contractors, including contractors in the Philippines. We engage them directly, not through freelance platforms or labour hire.
• Professional services. Accounting, legal, insurance and similar advisers, all based in Australia.
• Office and IT equipment. Laptops, phones and other electronics, office supplies, and building services such as cleaning, which the building owner or manager arranges.

We have about 5 direct suppliers. About 80 per cent of our supplier spend goes to suppliers based in Australia.

We considered where modern slavery could occur in our operations and supply chains, using the categories set out in the Australian Government's guidance: where we might cause it, contribute to it, or be directly linked to it through a supplier.

Our own operations. We think the risk in our own workforce is low. We have no employees. Our directors and contractors work in an office or online.

Contractors outside Australia. Where contractors work offshore, or are engaged through a third party, we have less sight of how they are recruited and paid. Recruitment fees, withheld pay and excessive hours are known risks in outsourced technology and support work. This risk applies to us, because some of our contractors work in the Philippines.

IT equipment. Electronics manufacturing, and the mining of the minerals used in electronics, carry a known risk of forced and child labour. We buy small quantities of standard equipment from large retailers and have little influence over this supply chain, but we are linked to it.

Cloud hosting. Data centres rely on hardware made in the same electronics supply chains, and on services such as cleaning, security and construction, which can carry labour risks. We buy these services from large providers.

Gift cards and rewards. Gift cards are digital, but they are spent at retailers whose own supply chains can carry modern slavery risks. We do not choose which retailers a gift card provider lists, and our link to these risks is indirect. Physical merchandise would carry a higher risk, but we do not supply it ourselves: the rare physical items in programs are supplied through the client (section 4).

Building services. Cleaning and security services are a recognised higher-risk sector in Australia. The building owner or manager arranges them for our Parramatta office, so our link to this risk is indirect.

Supplier due diligence. In the reporting period we listed our main suppliers by category and country, and identified the higher-risk ones: gift card supply, offshore contractors and building services. We have not yet sent supplier questionnaires.

Contract clauses. Our supplier and contractor agreements do not yet include modern slavery clauses. Adding them is one of our next steps.

Contractors. We engage contractors directly, pay them at agreed rates into their own accounts, charge no recruitment fees and do not hold their identity documents.

Training. No modern slavery awareness training has been done yet. Training the staff who engage suppliers and contractors is one of our next steps.

Raising a concern. Anyone can raise a concern about modern slavery connected to RewardCo by emailing legal@rewardco.com. We will treat concerns confidentially. A director of RewardCo is responsible for responding. We do not have a formal whistleblower policy.

Remediation. If we find modern slavery in our operations or supply chain, our first priority will be the people affected. We will work with the supplier to stop the practice and put things right, and we will end the relationship if the supplier will not act. We did not identify any cases of modern slavery in our operations or supply chains in this reporting period.

Next steps. In the next reporting period we plan to add modern slavery clauses to new supplier and contractor agreements, ask our gift card and payment providers (GiftPay, Gifted and Airwallex) about their own due diligence, and give the staff who engage suppliers and contractors awareness training.

We will review this statement and our actions each year. To judge whether our actions are working, we will track:

• how many of our higher-risk suppliers we have asked about modern slavery, and what they told us;
• how many new supplier and contractor agreements include modern slavery clauses;
• how many staff who engage suppliers have completed training; and
• any concerns raised, and how they were dealt with.

The directors review this statement each year. This is our first reporting period, and none of these measures were tracked in it.

Rewardco International Pty Ltd does not own or control any other entities, so there were no other entities to consult in preparing this statement.

The directors prepared this statement, with the staff who manage suppliers and contractors.

Clients and agencies can ask us for information about our approach to modern slavery for their own reporting. Email legal@rewardco.com.

This statement was approved by the board of directors of Rewardco International Pty Ltd on 1 November 2026.

Signed by a director of Rewardco International Pty Ltd:

Name

Chidi Okechukwu

Title

Director

Signature

To be signed

Date

1 November 2026