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Statement | Family 1, Corporate & Entity
A voluntary statement, made in the form required by section 16 of the Modern Slavery Act 2018 (Cth).
This document is the source of truth for: au-modern-slavery-statement, marketing:/au/legal/modern-slavery
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STM-AU-031 | Version 1.0.0 | Last Modified On 01 August 2026
A voluntary statement, made in the form required by section 16 of the Modern Slavery Act 2018 (Cth).
Edsol Edtech Pvt. Ltd. is not a reporting entity under that Act. Its annual consolidated revenue is
below the reporting threshold and it does not meet any other criterion for mandatory reporting. It makes
this statement voluntarily and to the mandatory criteria, because the obligation cascades: Australian
hospital groups, State health services and large not-for-profit operators are reporting entities, and
they discharge their obligation by sending supplier questionnaires. Having the answer already written,
published, dated and approved turns a week-long questionnaire cycle into a link.
It is written to the mandatory criteria, not around them, so that a procurement reviewer can map it
line by line to the questions they are required to ask. STM-GL-031 is the global statement and is not
repeated here; this document is the Australian-form instrument derived from it.
| Item | Value |
|---|---|
| Entity | Edsol Edtech Pvt. Ltd., trading as Pensieve Labs |
| Entity type | Private Limited Company, incorporated in India |
| Company identifier | [TO BE SUPPLIED] |
| Registered office | `28, Jamunather |
| Bulandshahar | |
| Uttar Pradesh | |
| India` | |
| Australian Business Number | Pensieve au abn |
| Reporting period | 1 April to 31 March |
| Basis of this statement | Voluntary. Below the reporting threshold; not a reporting entity |
| Entities owned or controlled | See Criterion 6 |
Structure. Edsol Edtech Pvt. Ltd. is a single operating company. Its ownership and control are
declared in STM-GL-029. It has no Australian subsidiary, no Australian office and no Australian
employees unless a particular customer agreement records otherwise.
Operations. Edsol Edtech Pvt. Ltd. designs, builds, deploys, hosts and supports Pensieve,
an operating system for hospitals. Its work is software engineering, cloud operations, implementation and
support, performed from India. It manufactures no physical goods, operates
no factory, warehouse or logistics network, employs no manual or agricultural labour, and does not
construct or fit out premises.
Supply chain. The supply chain is short and is almost entirely services and software:
| Tier | What it is | Modern slavery relevance |
|---|---|---|
| Cloud infrastructure | The hosting provider named in DIS-GL-009 |
The provider is a large listed enterprise with its own published modern slavery reporting. Indirect exposure sits in its data centre construction and hardware manufacture, several tiers removed |
| Software and platform services | Development, security, monitoring, communications and business tooling, each listed in DIS-GL-009 |
Low. Predominantly enterprise software from reporting entities |
| Professional services | Legal, accounting, audit, insurance, tax and security testing | Low. Regulated professions |
| Contractors and contingent engineering | Individual specialists engaged directly, on written terms | The most direct exposure Pensieve has, and the one it controls (Criterion 4) |
| Hardware | Employee laptops and peripherals; hospital-supplied hardware for on-premise deployments | The highest inherent-risk category, because electronics manufacturing carries documented forced-labour risk. Purchased from established resellers of major manufacturers |
| Office and facilities | A single office | Cleaning and facilities services are a known risk category in any market |
Pensieve does not supply labour into Australia, and its Australian delivery is remote. The primary Australian relevance of this statement is therefore its position as a supplier in a reporting entity's own supply chain, not its own operations in Australia.
Assessed as the risk that Edsol Edtech Pvt. Ltd. causes, contributes to, or is directly linked to
modern slavery practices.
| Risk | Assessment | Reasoning |
|---|---|---|
| Causing modern slavery in its own operations | Low | Salaried professional workforce, written contracts, wages above the applicable statutory minimum, no recruitment fees charged to workers, no retention of identity documents, no forced or child labour |
| Contributing through contracting practices | Low to moderate | The realistic exposure is engaging a contractor through an intermediary whose own arrangements are not visible. Addressed by direct written engagement (Criterion 4) |
| Directly linked through hardware manufacture | Moderate, and inherent to the sector | Electronics manufacturing carries documented forced-labour risk in upstream tiers. Pensieve buys small volumes through established channels and has no visibility beyond tier one |
| Directly linked through cloud infrastructure | Low at tier one, unquantified beyond it | Providers publish their own statements. Data centre construction and hardware supply sit beyond Pensieve's line of sight |
| Directly linked through facilities services | Low to moderate | Cleaning and security services are a known risk category |
| Geographic and sector risk | Considered | Pensieve operates in a market with documented bonded and child labour risk in some sectors. Its own sector (professional software engineering) is not among them, and the statement says so rather than either ignoring the point or overstating it |
Pensieve does not claim its supply chain is free of modern slavery. It claims that it has looked, that it has identified where it can see and where it cannot, and that it has acted where it has influence. A statement claiming a clean supply chain beyond tier one would not be credible from any company of Pensieve's size.
| # | Action | Status |
|---|---|---|
| 1 | Policy. A published prohibition on forced labour, bonded labour, child labour, human trafficking, debt bondage, the charging of recruitment fees to workers and the retention of identity documents, binding on every worker and every supplier | In place: STM-GL-031 Section 3 |
| 2 | Direct engagement of contractors. Every contractor is engaged on written terms directly with Edsol Edtech Pvt. Ltd., paid directly, and paid at or above the applicable statutory minimum. No labour-hire intermediary is used |
In place |
| 3 | No recruitment fees, no document retention. No worker is charged a fee to obtain or keep work, and no identity document is held by Edsol Edtech Pvt. Ltd. |
In place |
| 4 | Supplier terms. Modern slavery representations and a right to terminate for breach are in the standard supplier terms, and modern slavery is a criterion in supplier assessment under POL-GL-120 |
In place |
| 5 | Supplier register. Every supplier that handles data is listed with its function and location in DIS-GL-009, which is public and is maintained live |
In place |
| 6 | Grievance channel. A worker, a contractor or any person in the supply chain may report a concern to info@pensievelabs.org or through the channel in POL-GL-066. Reports may be made anonymously, and no person is disadvantaged for making one in good faith |
In place |
| 7 | Hardware procurement. Purchasing preference for manufacturers that publish their own modern slavery or responsible sourcing reporting | In place, tier one only |
| 8 | Remediation commitment. Where modern slavery is identified in Pensieve's operations or supply chain, Pensieve will act to remediate the harm to the affected person first, and will not treat termination of the supplier as remediation | Committed |
| 9 | Training. Modern slavery awareness for the people who engage contractors and suppliers | Outstanding: scheduled for the current reporting period |
| 10 | Supplier questionnaire. A short modern slavery questionnaire issued to new suppliers in the higher-risk categories in Criterion 3 | Outstanding: scheduled for the current reporting period |
Items 9 and 10 are outstanding and are stated as outstanding. A statement that reports only completed actions is less useful to a reviewer than one that reports the gap and the date.
Effectiveness is assessed annually, before this statement is re-issued, against measures that can actually be evidenced rather than asserted:
| Measure | How it is assessed |
|---|---|
| Every contractor engaged directly, on written terms, in the period | Count of engagements, and count made through an intermediary. Target: zero through an intermediary |
| Every worker paid at or above the applicable statutory minimum | Payroll review |
| No recruitment fee charged and no identity document retained | Confirmed at each engagement |
| Modern slavery terms present in every new supplier contract | Contract register review |
| Grievance reports received, and their outcomes | Count and disposition. A count of zero is reported as a count of zero, not as evidence of absence |
| Higher-risk suppliers assessed | Count assessed against count in the category |
| Actions 9 and 10 delivered | Delivered or not, with a revised date if not |
The limitation, stated. Effectiveness assessment for an entity of Pensieve's size cannot extend beyond tier one of the supply chain. Pensieve does not have, and does not claim, visibility into the manufacture of the hardware it buys or the construction of the data centres its provider operates. What it can do is control its own engagement practices completely, and it does.
Edsol Edtech Pvt. Ltd. owns and controls no other entity, so no consultation was required. Where that
changes, this statement will describe the consultation undertaken, and the ownership position in
STM-GL-029 will be updated first.
7.1 Why a sub-threshold entity publishes at all. Australian hospital groups and health services are reporting entities and must describe the actions they have taken to assess and address risks in their supply chains. Pensieve is part of that supply chain. Publishing this statement in the mandatory form, approved and signed, removes a questionnaire cycle from the procurement clock and gives the reviewer something they can attach to their own reporting.
7.2 The threshold may fall. A statutory review has recommended lowering the reporting threshold, which would capture a materially larger population of entities. That recommendation has not been implemented as at the Last Modified On date. Pensieve is positioned for it rather than exposed to it.
7.3 An Anti-Slavery Commissioner has been established under a 2024 amendment to the Act. Pensieve will comply with any request from that office and will co-operate with any Australian customer responding to one.
7.4 Related declarations. Anti-bribery and anti-corruption: STM-GL-030. Sanctions and export
control: STM-GL-032. Beneficial ownership and control: STM-GL-029. Vendor and third-party risk
management: POL-GL-120.
7.5 This statement is not lodged on the Australian register, because a voluntary statement from a
non-reporting entity is not required to be, and Pensieve does not imply that it is. It is published at
https://trust.pensievelabs.org and may be relied on and attached by any Australian customer.
This statement was approved by the principal governing body of Edsol Edtech Pvt. Ltd. on
01 August 2026 and is signed by a responsible member of that body.
| Signature | ____________________________ |
| Name | [TO BE SUPPLIED] |
| Position | Director |
| Date | 01 August 2026 |
| Document | For |
|---|---|
STM-GL-031 |
The global modern slavery and ethical sourcing statement this one is derived from |
STM-GL-029, STM-GL-030, STM-GL-032 |
Ownership, anti-bribery, sanctions |
DIS-GL-009 |
The supplier register referred to in Criteria 2 and 4 |
POL-GL-120 |
Vendor and third-party risk management |
POL-GL-066 |
The grievance channel referred to in Criterion 4 |
CHK-AU-001 |
Where this statement sits in the Australian readiness sequence |
| Version | Date | Author | Summary |
|---|---|---|---|
| 1.0.0 | 01 August 2026 |
Legal | First issue. Voluntary statement in the mandatory seven-criteria form, with the risk assessment, the completed and outstanding actions, the effectiveness measures and their stated limitation, and the approval block. |