Anti-Slavery and Human Trafficking Policy

SECTION 1: Policy Statement

Modern slavery is a fundamental violation of basic human rights and a crime. It can occur in any country, sector, or industry and takes various forms including slavery, servitude, forced or compulsory labor and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

In all cases, some of the most vulnerable people in society are stripped of their dignity and basic freedoms and forced to work for someone else’s gain or benefit. The most common forms of modern slavery are sexual exploitation and labor exploitation including child labor and domestic servitude.

We have a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chains. We expect the same high standards from all of our contractors, suppliers and business partners,

This policy applies to our Suppliers and all persons working for us or on our behalf in any capacity, including employees, directors, officers, interns, agents, contractors, and business partners

SECTION 2: Responsibility for the Policy

The Company’s directors and officers have overall responsibility for this Policy, including ensuring that it complies with legal and ethical obligations.

Human Resources and Compliance is primarily responsible for the day-to-day implementation of the Policy including monitoring its effectiveness and ensuring that all staff and franchisees are aware of, understand and comply with the Policy.

All staff are responsible for following the Policy to the extent that it affects their day-to-day work.

Human Resources and Compliance welcomes any questions or comments on this Policy and suggestions for ways in which it or procedures relating to the eradication of modern slavery might be adopted, adapted, or improved.

SECTION 3: Compliance with the Policy

All persons working for us or on our behalf in any capacity, including employees, directors, officers, interns, agents, contractors, and business partners are expected to:

• read, understand and comply with this Policy; and
• raise concerns with their manager, Human Resources, Legal, or Compliance regarding any suspicion that modern slavery might be occurring in any part of the Company’s business or in any of the Company’s supply chains at the earliest possible opportunity.

The Company wishes to encourage openness and will support anyone who raises a good faith concern that modern slavery might be taking place in any part of the Company’s business or in any of the Company’s supply chains, even if that concern ultimately turns out to be mistaken.

The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control.

This Policy also reflects the expectations that the Company has of its contractors, suppliers, and other business partners.

SECTION 4: Communication and Awareness of the Policy

This Policy is available on Our website and the Intranet. Training will be provided as necessary.

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

The Company expects its contractors, suppliers, and other business partners to provide similar training to their staff.

SECTION 5: Sanctions

Any breach of this Policy by officers and employees including in respect of their duties for the Company or in respect of their personal and domestic affairs may be dealt with under the Company’s disciplinary procedures and could result in dismissal.

In the event that the Company has a reasonable belief that modern slavery is occurring in any part of its business the Company will:

• put in place remedial action as soon as reasonably practical with a view to ensuring that such modern slavery ceases to occur and that the victims of that modern slavery are appropriately safeguarded; and
• monitor the effectiveness of the remedial action taken including the actions taken to safeguard the victims.

The Company may, depending on the facts, deal with the matter under its disciplinary procedures which could result in the dismissal of any officer or employee found to be responsible.

In the event that the Company has a reasonable belief that modern slavery is occurring in the business or supply chains of any contractors, suppliers and other business partners, the Company will expect the relevant contractor, supplier or other business partner:

• to be fully transparent and supply such information as the Company may reasonably request in relation to the issue;
• to put in place remedial action as soon as reasonably practical with a view to ensuring that such modern slavery ceases to occur and that the victims of that modern slavery are appropriately safeguarded;
• to monitor the effectiveness of the remedial action taken including the actions taken to safeguard the victims; and
• to report to the Company at reasonable intervals on the effectiveness of that remedial action and safeguarding and any further steps taken to ensure that such modern slavery ceases to occur.

The Company may, depending on the facts and the terms of the contract with the relevant contractor, supplier or other business partner, terminate or suspend the relationship or otherwise cease, reduce or minimize business contact with the relevant contractor, supplier, or other business partner.

SECTION 6: Amendments to the Policy

The Policy expresses the will of the Company and its commitment to the issues addressed. However, it does not in itself create any contractual obligations and may be amended by the Company at its discretion at any time.

The Policy will be reviewed by the Company’s directors and officers on a regular basis, typically annual or as local law requires.