Policies

 1. Introduction

Cornerstone Financial Pty Ltd (“CS Capital”) is committed to conducting business with integrity, transparency, and in full compliance with all applicable laws and ethical standards. We recognize that modern slavery, including forced labour, human trafficking, and child exploitation, is a significant global issue, and we are dedicated to identifying, mitigating, and preventing these risks within our operations and business relationships.

This statement affirms our commitment to combating modern slavery in alignment with the Modern Slavery Act 2018 and relevant international standards, applying to all employees, contractors, and business partners of CS Capital.

2. Our Business

CS Capital is a financial advisory firm located in Australia. Our business predominantly relies on a skilled workforce and external professional service providers, including legal, tax, accounting, and consultancy firms. While we do not engage in manufacturing or high-risk supply chains, we acknowledge that risks may exist within indirect procurement, outsourced services, and third-party relationships.

3. Our Values and Commitment

At CS Capital, we believe in:

• Ethical Business Conduct – Upholding integrity and accountability in all our business dealings.
• Respect for Human Rights – Promoting fair labour practices and safeguarding workers' rights.
• Service Provider and Partner Accountability– Ensuring our service providers and partners uphold the same high standards.
• Continuous Improvement – Regularly reviewing and enhancing our policies and processes.

CS Capital is committed to preventing modern slavery and promoting ethical labour practices across our business. Our approach includes:

• Governance and Leadership – Our management team oversees ethical business practices and compliance.
• Vendor and Supplier Due Diligence – We assess the ethical standards of service providers and suppliers before engagement.
• Policy Implementation – We maintain clear policies to prevent human rights violations in our operations.
• Whistleblower Protection – We provide a secure, confidential channel for employees and stakeholders to report concerns.
• Ongoing Monitoring and Improvement – We regularly review and strengthen our approach to modern slavery prevention.

4. Application 

This policy applies to all directors and employees of CS Capital, and any consultants or vendors working on behalf of CS Capital. It applies to all activities anywhere in the world. All CS Capital staff are required to read, understand and comply with this policy and to follow the requirements set out in this policy or in any relevant operational policies or procedures.

5. Defining Modern Slavery

Modern slavery encompasses situations where individuals are exploited through coercion, threats, or deception, effectively stripping them of their freedom. Globally, it is estimated that 40.3 million people are victims of modern slavery, with women and girls disproportionately affected, representing 71% of these victims. Notably, nearly two-thirds of modern slavery cases occur in the Asia-Pacific region.

Under the Modern Slavery Act 2018, modern slavery includes eight severe forms of exploitation:

1. Trafficking in persons: Involves recruiting, harbouring, or transporting individuals for exploitation, which can include sexual exploitation, forced labour, slavery-like practices, servitude, or organ removal.
2. Slavery: Occurs when an individual exercises ownership-like control over another person.
3. Servitude: Involves significantly restricting a person's freedom, preventing them from ceasing work or leaving their workplace.
4. Forced labour: Occurs when individuals are compelled to work against their will under threat or coercion.
5. Forced marriage: Happens when individuals are coerced, threatened, or deceived into marriage, or are incapable of understanding the nature of the marriage ceremony.
6. Debt bondage: Involves pledging services as security for a debt, where the debt is excessive, terms are unjust, or the services' duration and nature are undefined.
7. Worst forms of child labour: Situations where children are exploited through slavery-like practices, hazardous work endangering their health or safety, or involvement in illicit activities like drug production or trafficking.
8. Deceptive recruiting for labour or services: Occurs when individuals are misled about the nature of their employment, leading to exploitation through modern slavery practices.

Additionally, modern slavery can involve:

• Engaging in commercial transactions involving individuals subjected to slavery.
• Controlling, directing, or financing activities related to slave trading.
• Operating businesses that involve servitude or forced labour, including exercising control over or providing financial support to such enterprises.

6. Human Resources

We believe education and awareness are key to preventing modern slavery. CS Capital provides training to employees and key stakeholders on identifying and addressing modern slavery risks, with a focus on:

• Recognising signs of forced labour and exploitation.
• Understanding compliance requirements under modern slavery laws.
• Implementing ethical decision-making in procurement and business dealings.

7. Reporting 

CS Capital encourages employees, contractors, and external parties to report any concerns related to modern slavery. 

A key aspect of upholding ethical standards is ensuring that CS Capital personnel feel safe and empowered to speak up when there are reasonable grounds to suspect that CS Capital, its employees, or its suppliers are not acting ethically or in compliance with laws and obligations. 

The often-hidden nature of modern slavery practices makes them difficult to identify and report. It is crucial to respond in a manner that is safe, ethical, and respectful of the dignity and rights of those at risk or affected by modern slavery. Employees can raise any concerns with their immediate manager or report them confidentially to management. In Australia, the Australian Federal Police investigates suspected cases of modern slavery and can be contacted on 13 12 37 to discuss or report a suspected case.

8. Monitoring and Continuous Improvement

CS Capital is committed to continuously improving our approach to modern slavery prevention. We regularly:

• Review and update our policies and due diligence processes.
• Engage with industry bodies and best practice initiatives.
• Strengthen transparency in our operations and reporting mechanisms.