--- title: "Modern Slavery Statement — Lucid Labs" description: "Lucid Labs Pty Ltd voluntary Modern Slavery Statement, published in support of the Modern Slavery Act 2018 (Cth) and our supply-chain assurance commitments." url: "https://lucidlabs.com.au/modern-slavery-statement" --- # Modern Slavery Statement Reporting period: 1 July 2025 to 30 June 2026 (FY2026) · Approved 14 April 2026 · Voluntary statement **Reporting entity:** Lucid Labs Pty Ltd (ABN 33 678 306 539). Lucid Labs is below the AUD $100 million consolidated revenue threshold for mandatory reporting under the _Modern Slavery Act 2018_ (Cth) and is therefore not a “reporting entity” under that Act. Lucid Labs publishes this statement voluntarily as a matter of good corporate citizenship and to support our clients (including Australian Government clients and large enterprise customers) who require modern slavery disclosure from their supply chain. ## 1\. About Lucid Labs Lucid Labs Pty Ltd is an Australian-domiciled professional services company, registered in Queensland, with its principal place of business at 31 Hope Street, Spring Hill QLD 4000. Lucid Labs is a Microsoft Solutions Partner specialising in Data & AI, Microsoft Fabric, Microsoft Purview, Microsoft 365 Copilot and cloud solutions for clients in healthcare, government, agribusiness, financial services and not-for-profit sectors. Lucid Labs has a small number of employees, contractors and consultants, all engaged in Australia. The Company does not manufacture goods, does not operate physical premises beyond a shared office in Brisbane, and does not directly engage labour from high-risk jurisdictions. ## 2\. Our structure, operations and supply chain ### 2.1 Structure Lucid Labs Pty Ltd is a privately held proprietary company with a small number of shareholders, governed by a Board comprising the Chief Executive Officer (Gareth Saunders) and any other directors appointed from time to time. There are no subsidiaries or related foreign entities engaged in operations relevant to this statement. ### 2.2 Operations Lucid Labs’s operations are limited to: - the provision of consulting, design, development, implementation and managed services in respect of Microsoft cloud, data and AI technologies; - the development of small software products that supplement the consulting services; and - internal corporate functions (governance, finance, marketing, sales, HR). All Personnel are based in Australia and are engaged under Australian employment law (including the _Fair Work Act 2009_ (Cth)) or under written contractor agreements that warrant compliance with Australian law. ### 2.3 Supply chain Lucid Labs’s supply chain is short and dominated by tier-1 cloud and software providers: - **Cloud and software platforms** — Microsoft, GitHub, Xero, 1Password, Adobe. Very low risk; large global vendors with their own modern slavery statements and independent assurance. - **Professional services** — accountants, lawyers, insurance brokers. Very low risk; Australian-regulated professional firms. - **Office and facilities** — co-working operator, telecommunications carrier. Low risk; Australian-domiciled. - **Subcontractors** — independent consultants and contractors engaged for specific client projects. Low risk; Australian-resident, individually contracted, screened under the Lucid Labs Pre-Employment Screening Policy where applicable. - **Branded merchandise and marketing** — Australian print and merchandise suppliers. Low to moderate residual risk where base products may originate in higher-risk manufacturing jurisdictions. Lucid Labs does not procure raw materials, manufactured goods at scale, agricultural products, garments, electronics for resale, or labour from high-risk jurisdictions identified by the Walk Free Global Slavery Index. ## 3\. Risks of modern slavery in our operations and supply chain Based on a voluntary risk assessment conducted in April 2026, Lucid Labs has assessed the modern slavery risk in its operations and supply chain as **low overall**, with the following residual risk areas: - **Branded merchandise and marketing materials** — clothing and merchandise are typically printed in Australia but may incorporate base products manufactured in higher-risk jurisdictions. _Mitigation:_ Lucid Labs orders only from Australian suppliers who can demonstrate ethical sourcing. - **Subcontracted delivery resources** — where Lucid Labs engages subcontractors or labour-hire workers for client engagements, there is a low residual risk that those workers may be subject to underpayment or improper recruitment practices. _Mitigation:_ subcontractors are engaged under written agreements that include modern slavery warranties; the Lucid Labs Pre-Employment Screening Policy applies where the subcontractor meets the Sensitive Access Threshold. - **Tier-2 supply chain (suppliers of our suppliers)** — Lucid Labs has limited visibility of its tier-2 suppliers (for example, Microsoft’s hardware suppliers or its cleaning contractors). _Mitigation:_ reliance on the modern slavery statements published by tier-1 vendors, all of whom are themselves reporting entities under the _Modern Slavery Act 2018_ (Cth). ## 4\. Actions taken to assess and address modern slavery risks During the FY2026 reporting period, Lucid Labs has: - approved a **Modern Slavery Policy** (effective 14 April 2026, version 2.0) which sets out the Company’s commitments and expectations of Personnel and suppliers; - adopted a **Vendor Risk Management Policy** (effective 14 April 2026, version 1.0) which formalises supplier due diligence, including a modern slavery clause for inclusion in supplier contracts; - conducted a voluntary risk assessment of Lucid Labs’s supply chain; - reviewed the modern slavery statements of all Lucid Labs’s tier-1 strategic vendors (Microsoft, GitHub, Xero) and confirmed that each is a reporting entity under the _Modern Slavery Act 2018_ (Cth) and publishes an annual statement; - embedded modern slavery awareness into Personnel onboarding, the Lucid Labs Employee Code of Conduct and annual policy review training; and - established a reporting channel for modern slavery concerns, including an option to use the Company’s whistleblower channel under the Lucid Labs Fraud Policy. ## 5\. Effectiveness of our actions This is the first formal Modern Slavery Statement published by Lucid Labs and so direct year-on-year comparison is not yet possible. The Company will measure effectiveness in future reporting periods through the following indicators: - the number of supplier contracts containing the modern slavery clause; - the number of supplier responses to due diligence requests; - the number of modern slavery concerns raised through internal channels and how each was investigated and resolved; and - Personnel completion rates for modern slavery awareness training. ## 6\. Consultation Lucid Labs is a single proprietary company with no controlled entities; no inter-entity consultation was required for this statement. The statement was developed in consultation with the Lucid Labs Board (CEO) and reviewed against the policy register approved by the CEO. ## 7\. Approval This Modern Slavery Statement was approved by the Board of Lucid Labs Pty Ltd on **14 April 2026** and signed by **Gareth Saunders, Chief Executive Officer**, as the principal governing officer of the Company. ## 8\. Contact Questions about this statement, or to report a modern slavery concern, should be directed to: - Email: [privacy@lucidlabs.com.au](mailto:privacy@lucidlabs.com.au) - Post: 31 Hope Street, Spring Hill QLD 4000 In the event of immediate danger to a person, call **000**. This statement is published in support of the framework established by the _Modern Slavery Act 2018_ (Cth). It is voluntary and is not a registered statement under that Act.