Modern Slavery Policy

Brand Surge (CEJ Australia Pty Ltd, ABN 71 688 987 019)

Effective Date: 26 September 2026
Last Updated: 26 September 2026

1. Purpose and Scope

CEJ Australia Pty Ltd (ABN 71 688 987 019) trading as Brand Surge (Brand Surge, we, us or our) is committed to acting ethically and with integrity in all of our business relationships, and to implementing and enforcing effective systems and controls to help ensure that modern slavery is not taking place anywhere in our own business or in our supply chains.

This Modern Slavery Policy sets out our approach to identifying and managing modern slavery risk in our operations and supply chain. It applies to our directors, employees and, so far as reasonably practicable, to the suppliers we engage in the course of our business.

2. Our Commitment

We define modern slavery to include slavery, servitude, forced labour, human trafficking, debt bondage, forced marriage and the worst forms of child labour, consistent with the description used in the Modern Slavery Act 2018 (Cth) (Act). We do not tolerate modern slavery in any part of our business or supply chain and expect the same standard from the suppliers we work with.

3. Statutory Context

The Act requires entities that are Australian entities, or that carry on business in Australia, with annual consolidated revenue of at least $100 million, to lodge an annual Modern Slavery Statement with the Australian Government.

Brand Surge does not currently meet this reporting threshold, and this Policy is not a Modern Slavery Statement lodged under the Act. We have adopted this Policy voluntarily, reflecting our commitment to ethical sourcing and the direction of travel in Australian modern slavery regulation, and to give our customers and suppliers visibility of our approach.

4. Our Business and Supply Chain

Brand Surge supplies branded promotional merchandise, clothing and workwear to customers, primarily in Australia, from our base in Queensland. Our supply chain is described in more detail below.

4.1 Sourcing and Manufacturing

The products we sell are manufactured or sourced from a range of countries and regions, including China and Australia, among others, reflecting common practice in the promotional products industry.

4.2 Our Suppliers

We generally do not contract directly with overseas manufacturers. Instead, we source the majority of our products through established Australian-based suppliers and distributors, who in turn manage relationships with their own manufacturing and overseas supply partners. This structure means our direct visibility over offshore manufacturing conditions is generally obtained through, and depends on, the diligence of those Australian suppliers.

5. Modern Slavery Risks in Our Supply Chain

We recognise that the promotional products and apparel industry sources from regions and manufacturing sectors that are widely identified, including by government and industry bodies, as carrying an elevated risk of modern slavery practices, particularly in lower tiers of the supply chain that are not always visible to a business of our size.

We consider that our principal exposure to this risk arises indirectly, through the manufacturing and sourcing practices of the Australian suppliers and distributors we purchase from, rather than through direct contracting with overseas factories.

6. Supplier Expectations and Due Diligence

We expect the Australian suppliers and distributors we deal with to take reasonable steps to identify and address modern slavery risk within their own supply chains, including their relationships with overseas manufacturers.

As part of our ongoing approach to this Policy, we intend to: give preference, where commercially reasonable, to suppliers who can demonstrate awareness of modern slavery risk or who are themselves subject to modern slavery reporting or industry compliance obligations; ask key suppliers to confirm, on request, whether they have policies or practices in place to address modern slavery risk in their own supply chains; and raise any credible concern about modern slavery practices that comes to our attention with the relevant supplier and, if appropriate, escalate that concern in accordance with section 8 (Raising Concerns) of this Policy.

We do not currently operate a formal, documented supplier code of conduct of our own. We will keep this position under review as our business grows and as guidance for small and medium businesses under the Act develops.

7. Industry Membership and Collaboration

We are a member of the Australian Promotional Products Association (APPA), the peak industry body for the promotional products industry in Australia. We support APPA's role in promoting responsible industry standards and will have regard to any relevant guidance APPA issues concerning ethical sourcing and modern slavery risk in the promotional products sector.

8. Raising Concerns

Any employee, supplier or other person who becomes aware of, or has a genuine concern about, suspected modern slavery practices in connection with our business or supply chain should raise that concern with us as soon as possible using the contact details in section 10 (Contact Us). We will treat any such concern seriously and confidentially, and will take reasonable steps to investigate and respond appropriately.

9. Review of this Policy

We will review this Policy periodically, and in any event if our business grows to a point where the reporting threshold under the Act may apply to us, or if there is a material change to the Act or its reporting threshold.

10. Contact Us

If you have any questions about this Policy, or wish to raise a concern, please contact us at info@brandsurge.com.au, by post to PO Box 658, Marsden QLD 4132, or through our contact-us page.