ANTI-SLAVERY AND HUMAN TRAFFICKING POLICY STATEMENT

Modern slavery is a crime and a violation of fundamental human rights. It can take various forms, such as servitude, slavery, forced or compulsory labour, and human trafficking. All of these include the deprivation of a person’s liberty. This could be by another in order to exploit them for personal or commercial gain. Our commitment is to act ethically and with integrity in our business dealings and relationships. We are also committed to implementing systems and controls to ensure modern slavery is not taking place in our own business.

We have a commitment to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout supply chains. This is consistent with disclosure obligations we may have under applicable law. We expect the same standards from our contractors, suppliers, and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children.

WHO MUST COMPLY WITH THIS POLICY?

This policy applies to all persons working for us or on our behalf in any capacity. This includes employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

WHO IS RESPONSIBLE FOR THIS POLICY?

synvert TCM’s Chief Executive Offer and Operations Teams have overall responsibility for ensuring this policy complies with our legal and ethical obligations. They are also responsible to ensure that all those under our control comply with it.

synvert TCM’s Chief Executive Offer and Operations Teams have primary responsibility for implementing this policy. This is done through monitoring its use and effectiveness, dealing with queries, and reviewing internal control systems and procedures to ensure they are effective in countering modern slavery and human trafficking.

Management at all levels is responsible for ensuring those reporting to them understand and comply with this policy.

We review this policy regularly and may amend it at any time to update it with best practices and processes.

YOUR COMPLIANCE WITH THIS POLICY

You must ensure that you read, understand and comply with this policy.

Preventing, detecting, and reporting modern slavery in any part of our business or supply chains is the responsibility of those working for or with us. You are required to avoid any activity that may lead to a breach of this policy.

HOW AND WHEN TO NOTIFY IN CASE OF NON-COMPLIANCE

If you believe or suspect that a breach of this policy has occurred, or may occur in the future, you must inform the Operations Teams as soon as possible at hr@synvert-tcm.com.

We encourage you to raise concerns about any issue or suspicion of modern slavery. This is in any part of our business at the earliest possible stage.

If you are unsure about whether a particular act constitutes any of the various forms of modern slavery, raise it with the synvert TCM Operations Team. You can do this at the email address above.

We encourage openness and will support anyone who raises genuine concerns in good faith under this policy.

BREACHES OF THIS POLICY

Any employee who breaches this policy may face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.