Modern Slavery Statement
FY25
This Statement has not been approved by the Attorney-General's Department or published on the Australian Government's Modern Slavery Statements Register.
FY25 Annual Reporting Suite
This Modern Slavery Statement (Statement) has been prepared by Northern Star Resources Ltd ABN 43 092 832 892 (Northern Star) to meet the requirements of the Australian Modern Slavery Act 2018 (Cth) for the financial year ending 30 June 2025 (FY25).
Unless expressly stated otherwise, all references to 'our', 'we', 'us', the Company or Northern Star refer to the Group, as detailed on pages 16 and 17 in Our Corporate Structure. Please refer to the Glossary for the definitions of the capitalised terms used in this Statement.
The percentage figures disclosed in this Statement are subject to rounding and may not add to 100%. The full 2025 Annual Reporting Suite is available at https://www.nsrltd.com
Table of Contents
FY25 Annual Report
FY25 ESR
Reporting Suite
FY25 Corporate Governance Statement
FY25 Modern Slavery Statement
Introduction 4Highlights 4
Message from the Chair of the ESS Committee 4
About this Statement 6This Statement 6
Mandatory criteria 7
Modern Slavery Risks 24Our modern slavery risks 24
Action Taken to Address Risks 26Collaboration & engagement 26
Training & awareness 27
Risk identification and assessment 28
Supplier due diligence 30
Acknowledgement of Country
Northern Star would like to acknowledge and pay our respects to Traditional Owner groups, upon whose land in Australia we are privileged to work on.
Darlot
Kakarra
Kariyarra
Kariyarra Pirnthurruna
Kultju
Marlinyu Ghoorlie
Ngarla
Ngarluma
Ngarluma (Mallina)
Nyalpa Pirniku
Nyamal
Tjiwarl
Wajarri Yamatji
Warlpiri, Gurindji and Jaru
Whadjuk Noongar
the Wiluna Martu
Yinhawangka
Northern Star would like to acknowledge and pay our respects to the Athabascan people, upon whose ancestral lands our Pogo Operation in Alaska, is situated.
We seek and value the guidance and input of these indigenous groups in the operation of our business. We acknowledge their strong and special physical and cultural connections to their
Consultation with Group entities 7
Our progress 9
About Northern Star Resources Ltd 10Our Company 10
Our Purpose 11
Our STARR Core Values 11
Our workforce 12
Our Operations 13
Our corporate structure 16
Our supply chain 18
Modern Slavery Risk Management 20Modern slavery risk 20
Corporate governance 21
Policies & frameworks 22
Grievance mechanisms
& remediation 23
Case Study: Ongoing renewable
energy supply chain assessment 33
Case Study: Supplier refusal to audit termination 34
Assessing Effectiveness 36 Planned Actions for FY26 38 Glossary 40ancestral lands and pay our respects to their Elders, past and present. Cover Photo: Anna Tetley - Environmental Advisor
Jundee Operations
Yandal Production Centre, Western Australia
Highlights
87%
of key accountable
Introduction
Introduction
Message from the Chair of the ESS Committee
Nadine Kupke - Dump Truck OperatorThunderbox Operations Yandal Production Centre, Western Australia
employees have completed awareness training.1
100%
Completion
of our awareness training by the leadership team and all our Non-Executive Directors.
Tier 3
supplier SAQ pilot process completed. See case study page 33.
0
whistleblower reports related to modern slavery or other human rights abuses.
13
audits2 completed on our Tier 1 suppliers' practices.
I am pleased to present Northern Star's FY25 Modern Slavery Statement, which outlines our ongoing commitment to mitigating the risks of modern slavery across our Operations and supply chains.
We are proud of the progress we have made this year, including: conducting a coprehensive review of our supplier data and analysis processes, achieving a high compliance rate for our modern slavery awareness training among all required employees, and further strengthening our overall risk management approach to modern slavery.
In FY25, we focused on deepening our understanding of modern slavery risks within our supply chains. Notably, we continued a detailed assessment of Tier 2 and Tier 3 suppliers within
the supply chain of our Tier 1 solar panel supplier, our FY24 case study.
This year, we expanded our work to include a full Self-Assessment Questionnaire (SAQ) process for selected Tier 3 suppliers identified during our FY24 supply chain mapping project.
We collaborated closely with both Tier 1 and Tier 2 suppliers to uncover and address potential risks. Through this process, we gained valuable insights that we and our suppliers will apply across broader areas of our supply chain in the future.
While we did not identify any confirmed instances of modern slavery in FY25, we responded to a report concerning one of our
suppliers potentially in breach of our Supplier Code of Conduct procedure regarding modern slavery. We
implemented our full modern slavery due diligence process and used this case to identify areas for improvement in our processes, which we plan to address in FY26. In an effort to try
to ensure that human rights are not violated by suppliers in our supply chain, it is important to Northern Star to continue to try to engage with suppliers who attempt to disengage as a result of Modern Slavery concerns being raised with them.
We recognise that continuous improvement is essential to achieving meaningful and lasting impact. We remain supportive of the Australian Government's efforts to strengthen the Modern Slavery Act 2018 (Cth).
Looking ahead to FY26, we will prioritise improving supplier response rates to due diligence activities, enhancing the accuracy of risk identification through deeper supply chain analysis, and continuing to assess the effectiveness of our actions.
Sally LangerChair - Environmental, Social & Safety Committee
Northern Star Resources Ltd
20 August 2025
1 The total number of key accountable employees at 30 June 2025 is 368.
2 Audits completed in FY25 were both initial supplier audits and follow-up audits of CAPs issued.
4 5
About this Statement
About this Statement
Consultation with Group entities
This Statement has been approved for release by the Northern Star Board of Directors and is current as at 20 August 2025. The Statement is a joint statement by Northern Star for itself and all of its wholly owned
subsidiaries (the reporting entity), in accordance with section 14(2)(d)(ii) of the Act.
Northern Star prepared this Statement in consultation with each other reporting entity that this Statement covers (all of which have three common directors with Northern Star), in accordance with section 14(2)(c) of the Act. Consultation
was undertaken by our Group-wide Modern Slavery Working Group, which comprises members
of the Legal, Company Secretarial and ESG Engagement teams, who engaged with key areas of the business (including human resources, procurement, and community).The
Statement was approved by the Board following recommendations by the Environmental, Social & Safety (ESS) Committee.
This Statement
As prescribed by the Act, this Statement covers:
reporting entities covered by this Statement;
company structure, operations and supply chain;
modern slavery risks in our Operations and supply chain;
actions we have taken to assess and address those risks, including audits and corrective actions;
how we assess the effectiveness of such actions;
how we consult with our subsidiary entities; and
other information we consider relevant regarding our efforts to combat modern slavery in our Operations and supply chains.
This Statement is available on our website at: https://www.nsrltd.com and via the Australian Government's Online Register of Modern Slavery Statements at https://www.modernslaveryregister.gov.au.
Stuart Tonkin Managing Director & CEO Northern Star Resources Ltd20 August 2025
Mandatory criteria
This table outlines where the mandatory reporting criteria required by the Act have been addressed in this Statement:
Criteria | Section of this Statement | |
Identify the reporting entity. | About this Statement Our corporate structure | page 6 pages 16-17 |
Describe the structure, operations, and supply chains of the reporting entity. | About Northern Star Resources Ltd | pages 10-23 |
Describe the risks of modern slavery practices in the operations and supply chains of the reporting entity, and any entities that the reporting entity owns or controls. | Modern slavery risks | pages 24-25 |
Describe the actions taken by the reporting entity and any entity that the reporting entity owns or controls, to assess and address those risks, including due diligence and remediation processes. | Action taken to address risks | pages 26-35 |
Describe how the reporting entity assesses the effectiveness of such actions. | Assessing effectiveness | pages 36-37 |
Describe the process of consultation with any entities that the reporting entity owns or controls. | Consultation with Group entities | page 7 |
Any other relevant information. | Introduction Planned Actions for FY25 | page 4 page 38 |
Jundee Operations
Yandal Production Centre, Western Australia
6
Northern Star Resources Ltd FY25 Modern Slavery Statement 7
Introduction
Our progress
Northern Star is committed to continuous improvement in all aspects of our business Operations, and this extends to our commitment to take meaningful steps to identify and mitigate modern slavery risks and maintain responsible and transparent supply chains.
100
100% completion of our modern slavery awareness training by the leadership team and all our Non-Executive Directors.
Progress against the planned actions in FY25 committed to in our FY24 Statement is shown below:
Complete
See Training & awareness on page 27 for more detail.
Complete
100
100•
Complete
Complete
Complete
Complete
Complete
9
Refresh our Inherent Risk Assessment across all Tier 1 suppliers, to ensure the most up to date product and country risk profiles are considered.
See Audit and corrective action plans page 32.
100
Audit at least four Tier 1 suppliers who are labour hire companies and long-term contractors providing services to Northern Star against governance aspects within the Supplier Code
of Conduct and confirm progress against any corrective action plans issued.
See Inherent risk page 30 for more detail.
Set goals for effectiveness, where applicable, and measure our performance against the key performance metrics detailed in Table 8.
See Table 8 page 37 for FY25 goals.
100
Assess and enforce our Supplier Refusal to SAQ3 Procedure in relation to continued non-responses or refusal to complete SAQs.
See SAQ page 31 for more detail.
100
Utilising vendor management software to achieve enhanced assessment of ESG performance by our Tier 1 suppliers when awarding contracts via the tender process.
100
Complete supply chain mapping of our Tier 3 suppliers in the Jundee FY24 pilot assessment and investigate the modern slavery risk via a detailed SAQ process on a selection of ten of these suppliers.
See Supply chain risk page 25 for more details.
See case study provided on page 33 for more detail.
8 Northern Star Resources Ltd FY25 Modern Slavery Statement
Pogo Gold PourPogo Operations Pogo Production Centre, Alaska
3 Supplier's own self-assessment questionaire.