Telstra Group LimitedASX: TLS

2025 Modern Slavery Act Statement

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Modern Slavery Act Statement

2025

Acknowledgement

We recognise and acknowledge the existing, original and ancient connection Aboriginal and Torres Strait Islander peoples have to the lands, waterways and sky country across the Australian continent. We pay our respects to their Elders and Ancestors. At Telstra, we are enriched by Aboriginal and Torres Strait Islander peoples' contribution to our organisation, and we commit to working together to build a prosperous and inclusive Australia.

About the artwork 'Connection'



Created by Bobbi Lockyer, a passionate Aboriginal artist hailing from Kariyarra Country in Port Hedland. This artwork represents Telstra's commitment to its customers, community, and the power of connection. The artwork combines the hand painting storytelling and symbols of the oldest continuous

culture in the world with the modern digital graphic design of the satellite sky.

Terms used

Throughout this report, the terms Aboriginal and Torres Strait Islander and First Nations are used interchangeably to reference Australia's First Peoples.



Telstra Modern Slavery Act Statement 2025



Contents

CEO statement 2

Who we are 4

Our approach 7

Our modern slavery risks 10

How we address our modern slavery risks 12

How we check the effectiveness of our actions 24

How we consult within our group 25

Our progress 33

Appendix 1: Reporting Entities 34

Appendix 2: Legislative criteria 35

Appendix 3: Glossary 36

Appendix 4: Additional information for the purposes 38

of Canadian reporting requirements

Reporting entities and disclosure notes

The Telstra Group has prepared this statement to meet the requirements of the Modern Slavery Act 2018 (Cth) (Australian Act), Modern Slavery Act 2015 (UK) (UK Act)

and Fighting Against Forced Labour and Child Labour in Supply Chains Act (CA) (Canadian Act).

This statement covers the Reporting Entities described in Appendix 1 of this report. Other than the Reporting Entities, no Telstra Group controlled entity meets the reporting entity criteria under the Australian Act, the UK Act or the Canadian Act.1

Capitalised terms and key concepts are defined in the Glossary of this report.

  1. This statement does not cover Telstra Super. Telstra Super is the trustee for the Telstra Superannuation Scheme. We do not consider Telstra Super to be a controlled entity as we do not meet the criteria for consolidation under financial reporting standards.

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    ‌Telstra Modern Slavery Act Statement 2025

    CEO statement

    Modern slavery exists in every country in the world today and alarmingly, the numbers are rising. The impact on the people and communities affected is inhumane and unacceptable and we

    do not walk past it.

    Acting as a responsible business is core to who we are at Telstra and part of the behaviours and habits that guide how we show up for our customers and our communities. We have a longstanding commitment to act in line with the United Nations Guiding Principles on Business and Human Rights (UNGPs), and we are committed to upholding these in our own operations, our supply chains and through the partners we work with.

    We do not tolerate modern slavery in any form. We continuously review our processes to identify concerning labour practices, resolve issues where we find them and try to improve conditions for people who have been impacted.

    We also work with our partners and suppliers on their own processes and in FY25, we launched two guidance documents to help them:

    • comply with the human rights and modern slavery requirements in our Supplier Code of Conduct, including how to reduce modern slavery risks in their own supply chains

    • put in place the mechanisms to surface concerns that could escalate into modern slavery if not addressed.

    For our Telstra team, we have improved our training as well

    as our supplier governance processes including risk monitoring, assessment and mitigation. We also launched an investigations and remediation protocol to guide our people if they do find

    a labour rights or modern slavery concern in our supply chains.

    We take our commitments in this area very seriously and we welcome feedback on this statement. We will continue to be vigilant in our own operations and supply chains and work with the Australian business community to help prevent and address modern slavery.

    FY25 highlights

    Supported uplift of our suppliers' modern slavery maturity by creating guidance documents to help them implement effective grievance mechanisms and comply with the human rights requirements in our Supplier Code of Conduct.

    For more information, see the Uplifting our Supplier Code of Conduct section of this report.

    Developed an investigations and remediation protocol to guide our people on how to deal with labour rights issues in our supply chains and sought feedback on the document from a third party which includes advice from modern slavery survivors.

    For more information, see the Human rights investigations and remediations protocol section of this report.

    Made significant progress to uplift supplier governance activities (risk methodologies and Know Your Supplier (KYS) processes) including implementing a new technology solution.

    For more information, see the Continuous improvement of supplier governance across Telstra section of this report.



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    Annual statement of disclosure

    Telstra Modern Slavery Act Statement 2025

    In FY25, we did not identify any instances of modern slavery in our operations or supply chains.

    We recognise this does not guarantee the absence of modern slavery, given the challenges in identifying it deeper in supply chains. We remain committed to ongoing due diligence to identify, prevent and mitigate modern slavery.

    We did identify some labour practices that concerned us.2 Finding these issues demonstrates that our processes are generally effective in identifying situations that could escalate into modern slavery. They also alert us to areas where we may need to reinforce our risk management approach. As part of our commitment to transparency, we have chosen to report them in this statement.

    The activities described in this statement generally apply across the Telstra Group as a whole. Reporting Entities Telstra Health, Digicel Pacific and Versent and certain owned or controlled entities in the Telstra Group, such as Fetch TV, are not fully integrated into Telstra operations. The activities of these entities in response to modern slavery risk may differ to that of the remainder of the Telstra Group. Where we have identified material differences in the activities of Reporting Entities, we have set these out in this statement.

    This statement is made pursuant to section 14 of the Australian Act, section 54(1) of the UK Act and section 11 of the Canadian Act, as relevant. It is a joint statement for the purposes of the Australian Act. It constitutes the statement of each of the Reporting Entities for the year ended 30 June 20253 and has been prepared in consultation with those Reporting Entities.

    Australian Act

    This statement was approved on behalf of the Telstra Group by the Board of Telstra Group Limited under section 14(2)(d)

    (ii) of the Australian Act on 12 August 2025.

    Vicki Brady

    CEO and Managing Director of Telstra Group Limited



    UK Act

    This statement was approved on behalf of Telstra UK Limited by the Board of Telstra UK Limited under section 54(6)(a)



    of the UK Act on 19 August 2025.

    Margaret Chan

    Director of Telstra UK Limited

    Canadian Act

    This statement was approved on behalf of Telstra Incorporated by the Board of Telstra Incorporated under section 11(4)(a)

    of the Canadian Act on 15 August 2025. In accordance with the requirements of the Canadian Act and in particular section 11 thereof, I attest that I, in my capacity as a director on the Board of Telstra Incorporated, have reviewed the information contained in the statement on behalf of the Board of Telstra Incorporated. Based on my knowledge and having exercised reasonable diligence, I attest that the information in the statement is true, accurate and complete in all material respects for the purposes of the Canadian Act for the 2025 financial year. I have the authority to bind Telstra Incorporated.

    Thomas Roark Stasko

    Director, Chief Executive Officer

    and President of Telstra Incorporated



    25 August 2025



  2. For more information, including on our approach to remediation, see the Constructive engagement with suppliers, Process to implement the Supplier Governance Framework, Ensuring fair treatment of agency workers, Proactive engagement with suppliers and Improving labour practices in our promotional products

    supply chain sections of this report.

  3. All disclosures in this statement are as at 30 June 2025, unless otherwise noted.

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