Effective Date: 1 December 2025
Version: 2.0
Issuing Entities:
- Strategic Global Holdings Pty Ltd (ACN 693 256 503)
- Superspeed.ai Pty Ltd (ACN 660 530 090), trading as Cushi.ai / Cushi.app
Governance Oversight: Group CEO, Strategic Global Holdings Pty Ltd
Review Cycle: Annual or earlier if required by law or operational change
1. INTRODUCTION
This Modern Slavery Statement outlines the actions taken by Superspeed.ai Pty Ltd (Cushi.ai / Cushi.app) to identify, assess, prevent, and mitigate modern slavery risks across our operations and supply chains. Although not currently mandated under the Australian Modern Slavery Act 2018 (Cth), we voluntarily publish this Statement to meet global ESG expectations and demonstrate rigorous ethical governance.
This Statement aligns with:
• Australian Modern Slavery Act 2018 (Cth)
• UN Guiding Principles on Business and Human Rights (UNGP)
• ILO Conventions
• OECD Due Diligence Guidance
• Global supply-chain transparency norms
2. ORGANISATIONAL STRUCTURE, OPERATIONS & SERVICES
Superspeed.ai Pty Ltd is an Australian technology company headquartered in Brisbane.
Our operations include:
• AI-enabled onboarding, compliance, and learning technologies
• Platform hosting and maintenance
• Engineering, data protection, and security functions
• Global cloud services, development partners, and professional services providers
We operate primarily in Australia with controlled international engagements supported by global cloud infrastructure.
3. SUPPLY CHAIN OVERVIEW
Our supply chains include:
• Cloud hosting and infrastructure vendors
• SaaS platforms and engineering partners
• Professional services (legal, accounting, cyber, risk)
• IT hardware providers
• International technical support vendors
Risk exposure varies based on geography, industry sector, subcontracting depth, and labour standards within upstream supplier layers.
4. MODERN SLAVERY RISK ASSESSMENT
Key potential risk areas:
• Hardware manufacturing in regions with known forced-labour exposure
• Offshore software development with varying employment protections
• Multi-layer subcontracting where transparency diminishes
• Global logistics and electronics supply chains
• Labour outsourcing markets with limited regulatory oversight
5. ACTIONS TAKEN TO DATE
Cushi has implemented the following controls:
• Supplier due diligence checks including ESG and labour-standards review
• Contractual clauses requiring adherence to ethical labour practices
• Preference for suppliers with modern slavery statements or ESG frameworks
• Internal policies on ethical procurement, anti-bribery, and conduct
• Training for procurement and leadership teams on labour risk indicators
• Annual review of emerging risk jurisdictions
6. ENHANCED DUE DILIGENCE REQUIREMENTS (ULTRA-GRADE ADDITION)
High-risk suppliers must:
• Complete an ESG/modern slavery questionnaire
• Provide evidence of compliance programs
• Submit corrective action plans (CAPs) where weaknesses identified
• Demonstrate third-party audit participation (where applicable)
7. SUPPLIER TIERING & RISK MAPPING (ULTRA-GRADE ADDITION)
Cushi maintains a three-tier supplier risk map:
Tier 1 – Direct strategic suppliers (cloud/infra)
Tier 2 – Professional services & development partners
Tier 3 – Hardware, logistics, high-risk jurisdictions
High-risk suppliers undergo annual review and formal re-assessment.
8. WORKER GRIEVANCE & REMEDIATION FRAMEWORK
Where modern slavery concerns arise, Cushi will:
• Engage the supplier immediately and initiate corrective review
• Suspend or terminate relationships where remediation is inadequate
• Work with suppliers to support affected workers where feasible
• Notify authorities where mandated
• Document all findings for governance reporting
9. KPIs FOR EFFECTIVENESS
Cushi measures effectiveness through:
• % of suppliers completing ESG/modern slavery screening
• Number of corrective actions issued and resolved
• Training completion rates for procurement and leadership
• Incidents reported and remediation outcomes
• Annual reassessment results for high-risk suppliers
10. CONSULTATION, GOVERNANCE & ACCOUNTABILITY
Oversight of this Statement is provided by:
• Chief Executive Officer (Accountable Executive)
• Data Protection & Compliance Lead
• Security & Governance Committee
Cross-department consultation occurs across engineering, procurement, and finance.
11. FUTURE COMMITMENTS (ULTRA-GRADE ENHANCEMENTS)
Cushi commits to:
• Publishing a Supplier Code of Conduct aligned with UNGP & ILO standards
• Establishing annual supplier engagement forums
• Expanding independent audit participation for high-risk categories
• Enhancing supplier onboarding documentation and attestations
• Improving transparency reporting across controlled entities
• Developing a supplier investigation escalation matrix
12. APPROVAL
This Statement has been approved by the CEO of Superspeed.ai Pty Ltd.
Peter Riley Djenie
Chief Executive Officer
Superspeed.ai Pty Ltd
1 January 2025
ANNEX A – DEFINITIONS
Definitions include: Modern Slavery, High-Risk Supplier, Subcontractor, Due Diligence, Corrective Action Plan, ESG.
VERSION CONTROL & GOVERNANCE
© 2025 Superspeed.ai Pty Ltd (ACN 660 530 090), trading as Cushi.ai / Cushi.app.
Part of the Strategic Global Holdings Pty Ltd Group (ACN 693 256 503). All rights reserved.
Privacy: privacy@cushi.ai | Security: security@cushi.ai | Support: support@cushi.ai