Anti-Slavery Policy Statement

ANTI-SLAVERY POLICY STATEMENT

This Anti-Slavery Policy Statement (the "Policy") is made and entered into as of Effective Date: Day Month Year by and between Company Name: with principal place of business at (the "Company"), and Approving Party Name: Title: (the "Approving Party").

RECITALS

WHEREAS, the Company is committed to conducting its business in compliance with applicable laws prohibiting slavery, servitude, forced labour and human trafficking (collectively, "Modern Slavery Laws"), and to ensuring that such practices do not occur in any part of the Company's operations or supply chains; and

WHEREAS, the Company recognises the responsibility to operate with respect for human rights and to implement due diligence, prevention, detection and remediation measures designed to identify and address the risk of modern slavery; and

WHEREAS, the Approving Party has authority to approve and adopt corporate policies on behalf of the Company and will ensure active oversight of this Policy.

NOW THEREFORE, in consideration of the mutual covenants set forth herein and other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the parties agree as follows:

1. DEFINITIONS

1.1. "Modern Slavery" means any act or practice that constitutes slavery, servitude, forced or compulsory labour, human trafficking, debt bondage or the withholding of identity documents to compel work, together with any related conduct prohibited by applicable Modern Slavery Laws.

1.2. "Supplier" means any person or entity that supplies goods or services to the Company, including contractors, sub-contractors and agents.

2. POLICY STATEMENT

2.1. The Company strictly prohibits the use of Modern Slavery in any aspect of its business. The Company shall not, and shall use reasonable efforts to ensure that its Suppliers do not, recruit, transport, transfer, harbour or receive persons by means of threat, force, coercion, abduction or fraud for the purpose of exploitation.

2.2. The Company will take all reasonable steps to prevent Modern Slavery and will promptly investigate and remediate any suspected or actual incidents of Modern Slavery in its operations or supply chains.

3. SCOPE AND APPLICATION

3.1. This Policy applies to all directors, officers, employees, subsidiaries and joint ventures controlled by the Company and, to the extent achievable, to Suppliers engaged by the Company. The Company will use contractual and monitoring measures to promote compliance among Suppliers.

4. SUPPLIER DUE DILIGENCE AND CONTRACTUAL REQUIREMENTS

4.1. The Company shall conduct risk-based due diligence on Suppliers to identify and assess the risk of Modern Slavery, including but not limited to review of Supplier policies, site visits, audits and contractual representations and warranties addressing compliance with Modern Slavery Laws.

4.2. The Company requires Suppliers to warrant, in writing, that neither the Supplier nor its subcontractors engage in Modern Slavery and to permit reasonable inspection and audit by the Company or its designees.

  The Company will require written warranties from Suppliers regarding compliance with Modern Slavery Laws.

5. REPORTING, INVESTIGATION AND REMEDIATION

5.1. The Company shall maintain procedures to enable confidential reporting of concerns regarding Modern Slavery. The Company will investigate reported concerns in a timely manner and implement remediation measures where appropriate, including collaboration with affected persons and relevant authorities.

6. TRAINING AND AWARENESS

6.1. The Company will provide appropriate training and guidance to personnel whose roles create a material risk of exposure to Modern Slavery and to personnel responsible for procurement and supplier management.

7. AUDITS, RECORDKEEPING AND MONITORING

7.1. The Company shall maintain records sufficient to demonstrate compliance with this Policy and applicable Modern Slavery Laws. The Company may conduct audits, either directly or through third parties, of operations and Suppliers where risk indicators are identified.

8. REMEDIES AND DISCIPLINARY ACTION

8.1. A breach of this Policy by an employee may result in disciplinary action up to and including termination for cause. A breach by a Supplier may constitute a material breach of contract and entitle the Company to remedies including termination, indemnification and recovery of costs associated with remediation.

9. CONFIDENTIALITY AND NON-RETALIATION

9.1. The Company will protect the confidentiality of individuals who report concerns in good faith. Retaliation against any person who reports suspected Modern Slavery in good faith or participates in an investigation is strictly prohibited and will result in disciplinary action.

10. MONITORING, REVIEW AND CONTINUOUS IMPROVEMENT

10.1. The Company shall periodically review this Policy and its implementation measures to ensure continued effectiveness and to adopt enhancements as appropriate. The Company shall document reviews and any material changes.

GENERAL PROVISIONS

Governing Law: This Policy shall be governed by and construed in accordance with the laws of without regard to conflict of laws principles.

Entire Agreement: This Policy constitutes the entire agreement between the parties with respect to its subject matter and supersedes all prior and contemporaneous understandings, agreements, representations and warranties, both written and oral, with respect to such subject matter.

Severability: If any provision of this Policy is held to be invalid, illegal or unenforceable in any respect, the validity, legality and enforceability of the remaining provisions shall not in any way be affected or impaired thereby and the parties shall endeavor to replace the invalid provision with a valid provision the effect of which comes closest to that of the invalid provision.

Notices: All notices required or permitted under this Policy shall be in writing and delivered to the contact details set forth herein or to such other address as either party may specify in writing.

Amendments and Waiver: No amendment to this Policy shall be effective unless it is in writing and signed by both parties. No waiver of any provision of this Policy shall be effective unless in writing and signed by the party granting the waiver.

Counterparts: This Policy may be executed in counterparts, each of which shall be deemed an original and all of which together shall constitute one and the same instrument.

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