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For the financial year ending 30 June 2025

Introduction

Australian Immigration Agency Pty Ltd as trustee for the PRD Holdings Trust, trading as Global Recruitment & Immigration Agency (GRIA), provides this voluntary Modern Slavery Statement in accordance with the Modern Slavery Act 2018 (Cth). While not legally required to report, GRIA is committed to ethical business conduct, transparent governance, and contributing to the global fight against modern slavery.

1. Entity Structure, Operations & Supply Chains

GRIA is an Australian-based recruitment and immigration services firm operating a dual-service model. It connects Australian employers in industries such as aged care, healthcare, construction, and hospitality with pre-vetted international talent and facilitates employer-sponsored visa pathways through its in-house division, the Australian Immigration Agency (AIA).

Entity Details

  • Legal entity: Australian Immigration Agency Pty Ltd as trustee for the PRD Holdings Trust
  • Trading name: Global Recruitment & Immigration Agency (GRIA)
  • Principal place of business: Level 54, 111 Eagle Street, Brisbane QLD 4000, Australia

GRIA operates the GRIA platform—a smart marketplace connecting global candidates, licensed overseas recruitment agencies, and Australian employers. The platform manages end-to-end recruitment, candidate profiling, immigration support, and compliance documentation.

Our supply chain includes:

  • Licensed international recruitment agencies based in countries including, but not limited to, the Philippines, India, Fiji and the Pacific Islands, South Africa, the United Kingdom, and Ireland—each operating under local legal frameworks for overseas employment and subject to GRIA’s onboarding, due diligence, and compliance verification processes
  • Australian employers, each of whom is required to have an active Australian Business Number (ABN) verified via the Australian Securities and Investments Commission (ASIC) register, and must also adhere to GRIA’s employment integrity standards, including fair work compliance and no record of labour breaches
  • Cloud infrastructure providers (AWS – hosted in Australia)
  • Technology and CRM providers (e.g., Migration Manager, HubSpot, Google)
  • Independent contractors and professional service providers

2. Modern Slavery Risks in Operations & Supply Chains

Given GRIA’s global recruitment function and involvement with migration pathways, we recognise the elevated risk of modern slavery in:

  • Overseas recruitment supply chains, particularly where low-wage labour or vulnerable worker populations are involved
  • Industries such as aged care, construction, and hospitality, which are known to have systemic labour exploitation risks
  • Reliance on overseas recruitment partners for candidate sourcing, where visibility of second-tier suppliers may be limited

Although GRIA does not directly employ overseas workers or operate outside Australia, we facilitate connections between workers and employers in higher-risk sectors, requiring vigilance and accountability.

3. Actions Taken to Assess and Address Risks

GRIA has taken the following actions to identify and reduce the risk of modern slavery:

  • Supplier vetting: All recruitment partners must be licensed and comply with their country’s legal frameworks for overseas employment, including agencies operating under the DMW/POEA in the Philippines and equivalent authorities in India, Fiji, South Africa, and other countries of operation.
  • Contractual safeguards: Supplier agreements include terms requiring compliance with anti-slavery laws and ethical recruitment practices.
  • Training: Internal onboarding includes awareness training on identifying risks and upholding ethical standards.
  • Platform controls: GRIA facilitates transparency through structured role tagging, documentation tracking, and agency-level visibility.
  • Due diligence: Before onboarding a new partner, GRIA assesses their compliance documentation, licensing, and track record.
  • Candidate education: GRIA ensures that international candidates understand their rights and reporting options prior to departure.
  • Candidate vetting: GRIA requires its international recruitment partners to perform rigorous candidate screening processes, including employment history checks, qualification verification, and authenticity validation of submitted documentation. In addition, AIA—the internal migration advisory arm of GRIA—engages Registered Migration Agents to conduct structured consultations with candidates once they receive offers of employment from Australian employers. These consultations help ensure candidates are informed, prepared, and aware of their rights and obligations before proceeding with migration.

4. Assessing Effectiveness

GRIA monitors and reviews its modern slavery risk management approach through:

  • Ongoing internal audits of recruitment partner compliance
  • Tracking and maintaining an up-to-date registry of recruitment agencies that are verified as legally licensed and actively regulated by their respective national or regional overseas employment authorities, ensuring continued eligibility to operate under GRIA’s ethical sourcing framework
  • Requiring revalidation of partner credentials annually
  • Logging and reviewing complaints or whistleblower disclosures
  • Maintaining candidate feedback loops to detect potential exploitation risks

As GRIA continues to grow, we will formalise KPIs related to ethical supplier engagement and expand candidate exit interviews post-placement to capture and respond to lived experiences.

5. Consultation with Subsidiaries

GRIA operates as a single legal entity with two business arms: GRIA and its in-house immigration division, the Australian Immigration Agency (AIA). As both units share operations, infrastructure, and governance, this statement reflects coordinated consultation between leadership across both service lines.

6. Other Relevant Information

  • GRIA plans to develop a Supplier Code of Conduct in FY2026 to further define expectations for ethical labour practices
  • We are exploring collaboration with Australian industry bodies to promote standardisation in ethical international hiring
  • As part of our onboarding process, future functionality will include an embedded ethics checklist for all agency partners
  • We will review and update this statement annually as our footprint and partnerships evolve

Approval

This Modern Slavery Statement was reviewed and formally approved by the Managing Director of the Australian Immigration Agency (AIA) and the Chief Executive Officer of GRIA, acting on behalf of the governing body. This approval reflects our shared accountability and commitment to upholding ethical recruitment practices and minimising the risk of modern slavery across all operations and supply chains.

Signed,

Ruby Fowdar
Managing Director
30 April 2025