Modern Slavery Policy

Ethical operations & responsible supply chains

Bubbalooba Pty Ltd (ABN 15 151 030 796) trading as PO Box Designs  ·  Version 1.0, July 2026

The document above is the authoritative version. This page reproduces its content for convenience.

1. Purpose & Scope

This policy reflects the commitment of Bubbalooba Pty Ltd trading as PO Box Designs to combating modern slavery. Although our annual consolidated revenue is below the AU$100 million mandatory reporting threshold under the Modern Slavery Act 2018 (Cth), we adopt this policy voluntarily because we supply tier 1 and tier 2 builders and government projects and we share their commitment to responsible, transparent supply chains.

This policy applies to all staff, directors, contractors, suppliers and our offshore manufacturing partner.

2. What Modern Slavery Means

Modern slavery describes serious exploitation where coercion, threats or deception are used to exploit a person and deprive them of their freedom. Under the Modern Slavery Act 2018 (Cth) it includes trafficking in persons, slavery, servitude, forced labour, forced marriage, debt bondage, the worst forms of child labour, and deceptive recruiting for labour or services. We regard any such practice as wholly unacceptable.

3. Our Operations & Supply Chain

Our supply chain includes aluminium and materials suppliers, our offshore manufacturing partner, powder-coating and finishing subcontractors, freight and logistics providers, and our Vietnam-based drawings team. We recognise that manufacturing and construction supply chains — particularly those with an offshore component — can carry elevated modern slavery risk, and we take that risk seriously.

4. Our Commitments

• Ethical conduct — we act lawfully and ethically in all business relationships and require the same of those we work with.
• Supplier expectations — we expect our suppliers, contractors and offshore partner to share our commitment, to comply with applicable labour laws, and to take steps to ensure modern slavery is not present in their own operations and supply chains.
• Due diligence — we engage directly with our offshore partner and key suppliers rather than relying solely on contractual assurances. We visit our manufacturing partners and maintain direct working relationships that give us visibility of their operations.
• Fair pricing scrutiny — where pricing is abnormally low, we ask why, as unexplained low cost can be an indicator of exploitative labour practices.
• Awareness — we make our staff aware of modern slavery risks and of how to raise concerns.
• Reporting concerns — any person who suspects modern slavery in our operations or supply chain is encouraged to report it. Concerns can be raised confidentially with the Managing Director.

5. Assessing Effectiveness

We review our supplier relationships and this policy periodically, focus attention on higher-risk parts of our supply chain, and update our practices as our understanding improves. Where we identify a genuine risk or instance of modern slavery, we will act to address it, including remediation and, where appropriate, ending the supply relationship.

6. Responsibilities & Review

The Managing Director holds overall responsibility for this policy and its implementation. This policy is reviewed periodically and updated to reflect changes in our operations, our supply chain and relevant legislation.