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ESG Policy

LAST UPDATED 1 JUL 2026

 

1. Purpose

This policy establishes Agili8's commitment to Environmental, Social & Governance (ESG) obligations, including its responsibilities under applicable anti-slavery, anti-corruption, and anti-bribery legislation. It ensures that Agili8 operates as a responsible, ethical, and sustainable organisation in the delivery of its extended reality (XR), artificial intelligence (AI), and computer vision solutions.

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The purpose of this policy is to:

  • Articulate Agili8's environmental commitments and its consideration of climate change as a relevant organisational issue, in accordance with ISO 9001:2015/Amd 1:2024, Clauses 4.1 and 4.2;

  • Define Agili8's social obligations, including a zero-tolerance stance on modern slavery and its commitment to human rights, fair labour practices, and diversity;

  • Establish Agili8's governance standards, including anti-corruption and anti-bribery principles aligned with Australian law and ISO 27001:2022; and

  • Ensure compliance with the Modern Slavery Act 2018 (Cth), the Criminal Code Act 1995 (Cth) (foreign bribery and corruption provisions), and other applicable Australian and international legislation.

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2. Scope

This policy applies to:

  • All Agili8 staff (full-time, part-time, and contractors), regardless of work location (office or remote);

  • All third-party vendors, suppliers, and partners engaged by Agili8 in the delivery of its products and services;

  • All business activities, including product development (XR, AI, computer vision), service delivery, training, consulting, and operational support; and

  • All jurisdictions in which Agili8 operates or has customers.

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3. Applicable Standards and Legislation

| Reference | Relevance |

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| ISO 9001:2015/Amd 1:2024, Clause 4.1 | Requires consideration of climate change as a relevant issue when understanding organisational context |

| ISO 9001:2015/Amd 1:2024, Clause 4.2 | Requires consideration of climate-related requirements of interested parties |

| ISO 27001:2022, Clause 5.1 | Leadership and governance commitment to information security |

| ISO 27001:2022, Annex A 5.1 | Policies for information security and ethical conduct |

| Modern Slavery Act 2018 (Cth) | Requires entities to report on modern slavery risks in operations and supply chains |

| Criminal Code Act 1995 (Cth), Division 70 | Foreign bribery offences |

| Criminal Code Act 1995 (Cth), Division 141 | Corruption of Commonwealth officials |

| Corporations Act 2001 (Cth) | Director duties, corporate governance, and record-keeping |

| Fair Work Act 2009 (Cth) | Fair employment practices and worker rights |

| Work Health and Safety Act 2011 (Cth) | Workplace health and safety obligations |

| Privacy Act 1988 (Cth) & Australian Privacy Principles (APPs) | Responsible handling of personal information as a social obligation |

| Competition and Consumer Act 2010 (Cth) | Fair and ethical business conduct |

| Climate Change Act 2022 (Cth) | Australia's emissions reduction targets; relevant to environmental context |

| National Greenhouse and Energy Reporting Act 2007 (Cth) | Framework for reporting greenhouse gas emissions; relevant for awareness |

| UN Sustainable Development Goals (SDGs) | Global framework informing ESG aspirations (non-binding reference) |

| UN Guiding Principles on Business and Human Rights | International framework on corporate human rights responsibility |

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4. Roles and Responsibilities

Roles and responsibilities are kept practical and may be combined where no conflicts of interest exist.

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| CEO (Document Owner) | Ultimate accountability for ESG compliance; approve this policy; ensure ESG principles are embedded in business strategy and operations; report to relevant stakeholders. |

| All Staff | Comply with this policy; report concerns related to modern slavery, corruption, bribery, or environmental violations promptly; complete required training. |

| Technical Lead | Ensure ESG considerations are embedded in the design and deployment of XR, AI, and computer vision products; assess environmental impact of digital infrastructure. |

| Office Administrator | Monitor and report on ESG-related compliance obligations; maintain ESG records; coordinate supplier assessments. |

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5. Environmental

5.1 Climate Change and Organisational Context

Agili8 acknowledges climate change as a relevant issue affecting its operating context, consistent with ISO 9001:2015/Amd 1:2024, Clauses 4.1 and 4.2. The organisation considers:

  • Whether climate-related risks or opportunities affect the delivery of its XR, AI, computer vision, and 3D training services;

  • The expectations of customers, employees, and partners regarding environmental responsibility; and

  • The potential impact of climate change on Agili8's supply chain, including technology hardware and cloud infrastructure providers.

This consideration is reviewed annually as part of the management review process (refer to QP03 Management Review).

5.2 Environmental Commitments

Agili8 is committed to:

  • Minimising its environmental footprint across all operations, including energy consumption, waste generation, and the environmental impact of its digital infrastructure and hardware (including XR headsets and compute devices);

  • Preferring cloud-hosted services and digital delivery models over physical alternatives where feasible, to reduce the need for physical travel, printed materials, and on-site hardware;

  • Selecting technology vendors and cloud providers that hold recognised environmental certifications or demonstrate climate-related commitments (e.g., Google's carbon neutrality commitments);

  • Responsibly disposing of electronic equipment (e-waste) in accordance with applicable state/territory environmental legislation and Agili8's QP21 Asset Management procedures; and

  • Encouraging a culture of environmental awareness among staff.

5.3 Sustainable Technology Delivery

Given that Agili8's primary product is immersive training and remote operations technology designed to replace physical travel and on-site activities, Agili8 recognises that its core business has an inherently positive environmental impact by:

  • Reducing the need for personnel to travel to remote or hazardous sites through remote operations and virtual training solutions;

  • Reducing the need to print on paper with digital checklists and workflows;

  • Enabling safety training in virtual environments rather than requiring physical equipment or site access; and

  • Supporting clients in reducing their own carbon footprint through more efficient and no-travel operations.

Agili8 is committed to communicating these sustainability benefits to customers and tracking them as part of its broader ESG reporting.

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6. Social

6.1 Modern Slavery and Human Trafficking

Agili8 has a zero-tolerance approach to modern slavery in all its forms, including forced labour, child labour, debt bondage, human trafficking, and servitude.

6.1.1 Our Operations

Agili8 is committed to ensuring that modern slavery does not occur within its own operations. This includes:

  • Employing all staff under fair, lawful employment contracts in accordance with the Fair Work Act 2009 (Cth) and applicable Modern Awards;

  • Paying all staff at or above minimum wage requirements;

  • Ensuring all staff have the right to work in Australia;

  • Not using forced, compulsory, or trafficked labour; and

  • Providing a safe working environment in accordance with the Work Health and Safety Act 2011 (Cth).

6.1.2 Supply Chain

Agili8 recognises that modern slavery risks may exist in its supply chain, particularly in relation to:

  • Technology hardware (XR headsets, compute hardware, sensors);

  • Electronic components used in XR and AI platforms; and

  • Third-party software and SaaS services delivered from jurisdictions with varying labour standards.

Agili8 takes the following steps to identify and address these risks:

  • Assessing modern slavery risks when onboarding new suppliers in accordance with QP10 Third Party Management Policy;

  • Preferring suppliers that hold ISO 9001, ISO 27001, or other certifications evidencing governance and ethical practices;

  • Including modern slavery and ethical labour representations in vendor agreements; and

  • Taking action where modern slavery risks are identified, including supplier escalation, remediation, or termination of the relationship.

6.1.3 Reporting

As a small business currently below the mandatory reporting threshold under the Modern Slavery Act 2018 (Cth), Agili8 voluntarily commits to assessing and documenting its modern slavery risks annually. Where Agili8 grows beyond the reporting threshold, a formal Modern Slavery Statement will be prepared and lodged in accordance with the Act.

6.2 Human Rights

Agili8 is committed to respecting human rights in its business activities, consistent with the UN Guiding Principles on Business and Human Rights. This includes:

  • Ensuring that XR, AI, and computer vision solutions deployed in operational environments do not infringe upon the privacy, dignity, or safety of the individuals who interact with them;

  • Conducting privacy impact assessments for products that capture personal or biometric-adjacent data (refer to QP16 Data Management Policy and QP25 Privacy Policy);

  • Not using AI or computer vision technology for surveillance, discrimination, or other purposes that violate human rights; and

  • Respecting the rights of all individuals in Agili8's workforce, regardless of their background, nationality, gender, age, or other protected attributes.

6.3 Diversity, Inclusion and Fair Employment

Agili8 is committed to a diverse and inclusive workplace, consistent with the values articulated in QP07 Code of Conduct. This includes:

  • Providing equal employment opportunities for all individuals, regardless of gender, race, age, disability, sexual orientation, religion, or any other protected attribute under applicable Australian anti-discrimination legislation;

  • Fostering a workplace culture that is respectful, inclusive, and free from harassment, bullying, or discrimination;

  • Ensuring fair and transparent remuneration practices; and

  • Supporting the professional development of all staff, regardless of background.

6.4 Community and Stakeholder Engagement

Agili8 recognises its responsibility to operate as a positive presence in the communities in which it operates. The organisation:

  • Supports clients operating in safety-critical sectors (Health & Safety, Remote Operations, Warehousing, Logistics) by delivering technology that genuinely improves worker safety and operational outcomes;

  • Engages transparently with customers, partners, and suppliers regarding its ESG commitments; and

  • Considers the broader societal impact of its AI and computer vision products, including their potential for misuse, and takes steps to prevent such misuse through responsible design and governance.

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7. Governance

7.1 Anti-Bribery and Anti-Corruption

Agili8 has a zero-tolerance approach to bribery and corruption in all its business dealings, whether in Australia or internationally.

7.1.1 Prohibited Conduct

The following conduct is strictly prohibited:

  • Offering, promising, giving, or authorising the payment of a bribe — whether in cash, gifts, entertainment, or any other benefit — to any person, including government officials, in exchange for business advantage;

  • Accepting or soliciting a bribe from any person;

  • Facilitating payments (payments to expedite routine government actions) — even where such payments are common practice in a particular jurisdiction;

  • Using a third party (agent, consultant, or distributor) to make or receive payments that would constitute a bribe if made directly; and

  • Engaging in conduct that constitutes corruption of a Commonwealth official under Division 141 of the Criminal Code Act 1995 (Cth) or foreign bribery under Division 70.

7.1.2 Gifts and Hospitality

Agili8 recognises that reasonable gifts and hospitality can be a legitimate part of business relationships. However, staff must:

  • Not offer, give, or receive gifts or hospitality where doing so could influence, or could reasonably be perceived to influence, a business decision;

  • Disclose any gifts or hospitality received above a nominal value (more than $50 AUD) to the CEO; and

  • Obtain CEO approval before offering any gift or hospitality above a nominal value to a customer, supplier, or government official.

All approved gifts and hospitality are recorded in the Gifts and Hospitality Register maintained by the Office Administrator.

7.1.3 Political Donations

Agili8 does not make political donations. No Agili8 funds, assets, or resources may be used for political campaign contributions or related activities. The only donations allowed are to registered Not-For-Profit charities.

7.2 Conflicts of Interest

All staff are required to:

  • Disclose any actual, potential, or perceived conflict of interest to the CEO as soon as it becomes apparent;

  • Not participate in decisions where a conflict of interest exists or could be perceived to exist; and

  • Not use their position at Agili8 to obtain personal gain at the expense of the organisation or its customers.

Disclosed conflicts of interest are recorded and managed by the CEO.

7.3 Whistleblowing and Reporting

Agili8 encourages all staff, suppliers, and other stakeholders to report concerns about actual or suspected:

  • Modern slavery, human trafficking, or forced labour in Agili8's operations or supply chain;

  • Bribery, corruption, fraud, or other financial misconduct;

  • Environmental violations; or

  • Other breaches of this policy or Agili8's Code of Conduct (QP07 Code of Conduct).

Concerns may be reported:

  • Directly to the CEO;

  • Via email to info@agili8.com; or

  • Through the formal whistleblower process established under the Corporations Act 2001 (Cth), where applicable.

Agili8 is committed to:

  • Protecting individuals who report concerns in good faith from retaliation, victimisation, or detrimental treatment;

  • Investigating all reports promptly and confidentially; and

  • Taking appropriate corrective action where breaches are confirmed.

7.4 Financial Integrity

Agili8 maintains accurate and transparent financial records in accordance with QP28 Financial Management Policy and applicable Australian accounting and taxation obligations. Staff must not:

  • Create false, misleading, or incomplete records;

  • Approve transactions they know to be improper; or

  • Circumvent financial controls for any purpose, including to facilitate payments that would constitute bribery or corruption.

7.5 ESG Governance and Reporting

The CEO is responsible for overseeing Agili8's ESG performance. ESG considerations are reviewed as part of the annual management review process (refer to QP03 Management Review) and include:

  • Assessment of whether climate change has become a more or less significant issue for the organisation;

  • Review of modern slavery risk in the supply chain;

  • Review of anti-bribery and anti-corruption controls and any incidents;

  • Assessment of diversity and inclusion outcomes; and

  • Consideration of any new or emerging ESG-related regulatory obligations.

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8. Training and Awareness

All staff are made aware of this policy upon commencement of employment. Training covers:

  • Agili8's environmental commitments and the relevance of climate change to its operations;

  • Modern slavery obligations, including how to identify and report concerns;

  • Anti-bribery and anti-corruption obligations, including the prohibition on facilitation payments;

  • Conflicts of interest and disclosure obligations; and

  • The whistleblower process and protections.

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9. Non-Compliance

Failure to comply with this policy may result in:

  • Breaches of the Modern Slavery Act 2018 (Cth), the Criminal Code Act 1995 (Cth), or other applicable legislation, with associated civil or criminal penalties;

  • Reputational, financial, or legal harm to Agili8 and its stakeholders;

  • Non-conformances identified during ISO 9001:2015 or ISO 27001:2022 audits; and

  • Disciplinary action in accordance with QP33 Non-compliance & Disciplinary Action.

Non-compliance must be reported to the CEO, who will initiate corrective action and document it in the corrective action log.

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10. Exceptions

Requests for exceptions to this policy must be submitted to the CEO with:

  • The nature and scope of the exception;

  • The business justification;

  • Proposed compensating controls; and

  • A proposed expiry date.

Approved exceptions are recorded in the Exception Register and reviewed at least annually.

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