Anti-Slavery Policy

1. Introduction

Sellarix ("the Company") is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain. This Anti-Slavery Policy reflects the Company's commitment to acting ethically and with integrity in all its business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in its business or supply chains.

2. Policy Statement

The Company acknowledges its responsibilities under the Modern Slavery Act 2015 and is committed to ensuring transparency within its organization and with suppliers of goods and services to the Company. The Company is opposed to modern slavery, human trafficking, forced labour, and similar human rights abuses.

3. Definition

Modern slavery encompasses slavery, servitude, human trafficking, and forced labour. The Company considers modern slavery to include:

• Human trafficking is where individuals are transported, harboured, recruited, or transferred through the use of force, coercion, abduction, fraud, deception, or abuse of power for exploitation.
• Forced labour, where individuals are coerced or deceived into providing labour against their will.
• Slavery, where individuals are treated as property and are forced to work through mental or physical coercion.

4. Responsibilities

The Board of Directors has overall responsibility for ensuring this policy complies with the Company's legal and ethical obligations and that all those under the Company's control comply with it. The Compliance Officer has primary and day-to-day responsibility for implementing this policy, monitoring its use, and dealing with any queries about it.

5. Risk Assessment

The Company assesses the risk of modern slavery and human trafficking within its business and supply chains, taking into account the nature of its business, sector, and geographical locations. The risk assessment is regularly reviewed and updated as necessary.

6. Due Diligence

The Company conducts due diligence on all suppliers before entering into contracts with them and regularly reviews existing suppliers to ensure compliance with the Anti-Slavery Policy.

7. Whistleblowing

The Company encourages all its employees, customers, and other business partners to report any concerns related to the direct activities or supply chains of the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.

8. Training

The Company provides training to all employees to raise awareness of modern slavery and human trafficking and to ensure compliance with this policy. Training is provided to relevant employees at induction and regularly thereafter.

9. Communication

This policy is communicated to all employees, suppliers, contractors, and other business partners and is made available on the Company's website.

10. Compliance

Any breach of this policy may result in disciplinary action, including termination of employment or contract.

11. Review

This policy is reviewed annually and updated as necessary to ensure its continued relevance and effectiveness in preventing modern slavery and human trafficking.