Modern Slavery Policy

We at Main Sequence are committed to acting ethically in all our operations and across our investment activities.

This includes continuously evolving how we can best integrate environmental, social and governance (ESG) issues to provide better outcomes for society and the people we work with. When it comes to modern slavery, we are committed to detecting and preventing it across both our investment activities and operations.
This Modern Slavery Policy has been incorporated into Main Sequence’s relevant internal policies and procedures (including our ESG Policy), which intends to consolidate Main Sequence’s commitment to the UN Principles of Responsible Investing.

What is modern slavery?

Modern slavery is the use of coercion, threats or deception to exploit victims and undermine their freedom and is a violation of human rights. The Modern Slavery Act 2018 (Cth) defines modern slavery to include eight types of serious exploitation - trafficking in persons, slavery, servitude, forced marriage, forced labour, debt bondage, the worst forms of child labour (situations where children are subjected to slavery or similar practices, or engaged in hazardous work) and deceptive recruiting for labour or services.

Modern slavery can occur in every industry and sector and has severe consequences for victims. Modern slavery also distorts global markets, undercuts responsible business and can pose significant legal and reputational risks to organisations. It is why we assess and consider the potential risk of exposure to modern slavery via the companies in which we invest on behalf of our clients, as well as the procurement of goods and services in our own operations.

Operational activities


As an investment manager, our supply chain is relatively straightforward. We work with service providers predominantly from professional advisory, information technology and consultancy sectors. This includes enterprise software and enterprise service providers such as legal, tax and accounting. Our financial and legal services are predominantly procured from the Commonwealth Scientific and Industrial Research Organisation (CSIRO) or trusted third parties. While we believe the risk of modern slavery and trafficking in our supply chains to be low, we look to assess and, where relevant, manage modern slavery risks whenever we procure services.


We have incorporated an assessment of modern slavery risk in our annual Risk review and will continuously improve how we evaluate this risk when we procure goods and services for our operations.
If we were to identify incidents of modern slavery in our business operations, they would be tracked internally, managed by the team directly, reported to the board of CSIRO Financial Services and appropriate remedial action taken. We would also seek to apply learnings to prevent future incidents.

Investment activities


Our integrated ESG approach includes an assessment of modern slavery risks in the companies we invest in (including operations and supply chain) and their impact on people. We continuously improve our approach to evaluating modern slavery across our investment portfolio and will be looking to improve our assessment and actions over time.


When assessing any new investment, we implement our due diligence process. Relevantly, this process aims to comprehensively identify, prevent and mitigate adverse human rights impacts, including modern slavery. When a business model, sector or geography is identified as high risk, we ensure thorough research and analysis into this area is completed, before investing in the company. It is also highlighted in the internal Deal Review Memos we prepare for our Investment Committee.
Our focus on modern slavery risk continues throughout the term of an investment. We take an active governance approach to our portfolio companies, where we typically hold board seats and have some influence in areas such as management of modern slavery risks on a continuous basis. We also conduct a formal semi-annual review of modern slavery across our portfolio and seek input from the founders of each investee company.
In general, our approach to assessing modern slavery risk within our investee companies is to:

  • Describe the risks of modern slavery practices in the operations and supply chains that may be present in the reporting entity and any entities it owns or controls; 
  • Describe the actions taken by the reporting entity and any entities it owns or controls to assess and address these risks, including due diligence and remediation processes; and
  • Describe how the reporting entity assesses the effectiveness of these actions and key learnings for the future.