Last revision: October 23, 2026
This Joint Modern Slavery and Human Trafficking Statement is published by Phenom People, Inc. and its subsidiaries and affiliates (jointly the “Phenom Group”) in compliance with Section 54 of the United Kingdom Modern Slavery Act 2015 and Section 16 of the Australian Modern Slavery Act 2018 (Cth). It details the actions taken by Phenom Group across its global business operations and supply chains to identify, prevent, and mitigate risks of modern slavery, human trafficking, forced labor, and severe labor exploitation.
1. Reporting Entities and Scope
This joint statement covers Phenom Group and all corporate entities within its global group structure, specifically including:
Phenom People, Ltd.
Australian Operations: Phenom’s United States entity, which carries on business in Australia (operating under Australian Business Number: 23 377 286 324) and whose consolidated group revenue meets or exceeds AUD 100 million.
References in this statement to “Phenom Group,” “the Group,” “we,” “us,” or “our” refer collectively to all global operating entities and subsidiaries controlled by Phenom Group.
2. Organisational Structure, Operations, and Supply Chains
2.1. Corporate Structure and Business Operations
Phenom Group is a global enterprise software company specializing in AI-powered talent experience solutions. Headquartered in the United States, Phenom Group operates subsidiary offices in the United Kingdom, the European Union (The Netherlands, Spain, Germany), Canada, Israel, and India. The vast majority of our workforce consists of skilled technology, sales, administrative, and corporate professionals employed directly under compliant contracts offering competitive wages, statutory benefits, worker well-being and development resources, and flexible working arrangements.
2.2. Supply Chain Profile
Our supply chains primarily support software development, cloud infrastructure, and administrative functions. Key vendor categories include:
Technology & AI Infrastructures, such as cloud platform providers and large language model developers, including entities processing personal data on Phenom’s behalf (see the list here).
Professional Services, such as legal, financial, and accounting consultancy services.
Facilities Management & Corporate Support mainly for office leasing and management, including physical security, commercial cleaning, or catering.
3. Risks of Modern Slavery in Operations and Supply Chains
Phenom Group evaluates modern slavery risks across our direct workforce and external supply networks by assessing geographic exposure, industry risk profiles, and business models.
3.1. Operational Risk
Because our direct workforce consists predominantly of skilled professional and technology workers operating under robust local employment regulations, the inherent risk of modern slavery within Phenom Group’s internal operations is assessed as low.
3.2. Supply Chain Risk
We recognize that elevated modern slavery risks exist within lower tiers of our supply chain and indirect services:
Hardware and Electronics Manufacturing: Global supply chains for IT hardware and server infrastructure carry inherent risks of forced labor, deceptive recruitment practices, and child labor at raw material extraction and component manufacturing levels.
Facilities & Contracted Site Services: Support services such as office cleaning, physical security, and catering rely on contingent labor models, which present higher sector-based risks of wage exploitation, third-party sub-contracting abuse, and excessive hours.
4. Policies and Governance Framework
Phenom Group maintains explicit governance policies that enforce ethical business practices, fair labor standards, and human rights compliance across all operational jurisdictions.
Employee Handbook: Mandates every employee to attest to promoting ethical behavior, equal opportunity, fair compensation, and strictly prohibits forced, involuntary, or child labor across all global operations.
Supplier Code of Conduct: Establishes mandatory requirements for all suppliers, contractors, and partners. Suppliers must commit to voluntary employment, safe working conditions, non-discrimination, compliance with local wage laws, and zero tolerance for human trafficking.
Whistleblower & Grievance Policy: Provides secure, anonymous, and confidential reporting channels for employees, contractors, and third parties to report suspected unethical behavior, illegal practices, or labor violations without fear of retaliation.
Procurement Due Diligence: Standardizes vendor onboarding, risk screening, and contractual compliance criteria.
5. Due Diligence Processes and Risk Mitigation
Phenom Group employs proactive due diligence processes to manage and mitigate modern slavery risks throughout our procurement lifecycle.
5.1. Supplier Screening and Onboarding
New vendors undergo risk-based pre-screening evaluated against country-of-origin risk indices, sector risk, and contract volume.
Standard commercial contracts require vendors to warrant compliance with the UK Modern Slavery Act 2015, the Australian Modern Slavery Act 2018 (Cth), and applicable local human rights laws. Contracts include audit rights and termination clauses for non-compliance.
5.2. Grievance Handling and Remediation
If modern slavery, forced labor, or human rights abuses are identified within our operations or vendor network, Phenom Group will:
a) Investigate allegations immediately through the Legal and HR functions.
b) Work with affected vendors to institute a swift, corrective remediation plan centered on worker safety and restitution.
c) Terminate commercial relationships with any vendor unwilling or unable to rectify non-compliance within a reasonable timeframe.
6. Entity Consultation Process
In accordance with Section 16(1)(f) of the Australian Modern Slavery Act 2018 (Cth), this joint statement was prepared through a coordinated consultation process involving leadership across all reporting and operating entities within the Phenom Group. Centralized compliance, legal, human resources, procurement, and operations leads representing both the US parent entity (carrying on business in Australia under an ABN) and UK operating entities were directly engaged to assess risk profiles, review vendor relationships, align policies, and approve the contents of this statement.
7. Training and Capacity Building
Phenom Group provides targeted guidance and training to key internal stakeholders:
All employees receive annual training on our policies during onboarding and annual policy renewals and are required to sign the Employee Handbook before employment begins.
Procurement, Finance, Talent Acquisition, and Vendor Management personnel receive specialized guidance on identifying modern slavery red flags, such as hidden recruitment fees, forced overtime, and unlawful retention of identity documents.
