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Modern Slavery Statement
1. Introduction
This voluntary Modern Slavery Statement has been prepared by Global X Management (AUS) Limited (“Global X” or the “Company”) and its subsidiary companies (“the Group”). Although Global X is currently not required to report under the Modern Slavery Act 2018 (Cth) (the “Act”), it is committed to identifying and addressing the risks of modern slavery across our operations, supply chains, and investment activities. We voluntarily publish this statement to demonstrate transparency and support for the eradication of modern slavery in all its forms.
We acknowledge the influence the investment management industry can have in promoting responsible practices and are committed to playing our part.
This Statement is made on a voluntary basis and has not been submitted to the Attorney-General’s Department.
2. Our Business
Global X’s business operations are limited to operating, managing and distributing investment funds that are exchange traded, predominately investing passively in portfolios of securities, derivatives or commodities.
Our operations are based in Sydney, Australia with services supported by external providers including custodians, index providers, administrators, and legal and audit professionals.
Our funds are open to investment by both wholesale and retail investors.
3. Relevant Policies
We have adopted a set of policies that support our commitment to identifying and managing risks associated with modern slavery. These include:
- Code of Conduct: Outlines the principles and standards that our directors, employees and contractors are expected to abide by when acting on behalf of the Company.
- Vendor Selection: Outlines how vendors are selected through a due diligence process that assesses their experience, service capabilities, and compliance with regulatory requirements. Ongoing oversight is conducted to ensure they maintain appropriate standards. All material vendor arrangements are subject to Board approval and are monitored to ensure alignment with Global X’s governance and risk management frameworks.
- Whistleblower Policy: Provides a safe channel for employees, suppliers, or other stakeholders to report unethical conduct, freely and without fear of repercussions when raise concerns regarding actual or suspected contraventions of ethical and legal standards.
- Risk Management Framework: Addresses material non-financial risks, and has an appropriate framework in place which outlines the structured approach to actively identifying, assessing and managing risk at Global X.
- Human Resources Policies: Outlines commitment to equal opportunity employment and to prevent any harassment and discrimination in the workplace. Global X has procedures in place concerning employment screening and appropriate workplace behaviour. All staff are expected to abide by these policies. Global X is committed to full compliance with these provisions.
The above policies are reviewed periodically and updated as needed to reflect regulatory expectations and evolving best practices.
4. Supply Chain
Global X engages with numerous suppliers in relation to its business operations. Our direct supply chain is composed primarily of:
- Professional service firms (registrar, legal, audit, tax)
- Technology and data service providers
- Custodians and fund administrators
- Facility management (e.g., office cleaning, catering)
While we assess our direct suppliers as generally low risk for modern slavery, we acknowledge the potential for risks to exist further down the supply chain and within the companies we invest in.
5. Risks of Modern Slavery Practices within the Supply Chain and Investment Process
Global X is committed to ensuring that appropriate risk-based strategies are in place throughout our business, including consideration of the risk of modern slavery and human rights issues.
Due to the nature of indexed fund investing, the Company and the Funds may be exposed to modern slavery practices via the following supply chain activities:
- Indirect and unintentional investment in companies which have the potential to be involved in modern slavery practices.
- The indirect and unintentional investment in issuers with global supply chains that are not always transparent or subject to strong labour protections
- The investment in emerging markets or jurisdictions with weaker human rights protections Investments in emerging markets or jurisdictions with weaker human rights protections.
We recognise that passive investment strategies can limit direct influence over underlying holdings. While we are not currently required to report under the Modern Slavery Act, we remain mindful of potential risks and will continue to observe developments in this area as part of our ongoing governance practices.
6. Governance and Approval
This statement was reviewed and approved by the Global X Board on 29 September 2025.
We are committed to improving our modern slavery risk management and welcome engagement with clients, investors, and the broader community.
7. Contact
For any questions or feedback regarding this statement, please contact our Risk and Compliance team:
- Phone: +61 2 8311 3488
- Email: info@globalxetfs.com.au
- Mail: Global X ETFs Australia, Level 9, 115 Pitt Street, Sydney NSW 2000