Modern Slavery Policy

1. Purpose

The purpose of this policy is to outline Masters in Mind’s commitment to preventing modern slavery and human trafficking in all its forms within our operations and supply chain. We are committed to acting ethically and with integrity in all our business dealings and relationships.

2. Scope

This policy applies to all employees, contractors, suppliers, and other business partners of Masters in Minds Ltd.

3. Definition

Modern slavery encompasses slavery, servitude, forced and compulsory labour, and human trafficking. We recognize that these practices constitute severe violations of fundamental human rights.

4. Commitment

Masters in Minds Ltd is committed to:

• Ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains.
• Upholding all laws relevant to countering modern slavery and human trafficking in all jurisdictions in which we operate.

5. Responsibilities

• Management: Ensure the policy is implemented effectively within their areas of responsibility, provide adequate resources for its implementation, and ensure their teams understand and comply with the policy.
• Employees: Comply with the policy and report any suspicions of modern slavery in any part of our business or supply chains.
• Suppliers and Contractors: Adhere to our commitment to tackling modern slavery and to the ethical standards outlined in this policy.

6. Due Diligence

We undertake due diligence to identify and mitigate the risks of modern slavery within our operations and supply chains by:

• Conducting risk assessments to identify parts of our business and supply chain where there is a risk of modern slavery.
• Evaluating the modern slavery and human trafficking risks of new suppliers through a robust vetting process.
• Requiring all suppliers to confirm they do not engage in modern slavery and adhere to our ethical standards.

7. Training

All employees and management will receive training on modern slavery to ensure they understand the signs of modern slavery, the risks to our business, and how to report any suspicions.

8. Reporting and Whistleblowing

Employees, suppliers, and other business partners are encouraged to report any concerns related to modern slavery and human trafficking. Reports can be made through:

• Confidential whistleblowing hotlines or email.
• Direct reporting to management or HR.

All reports will be investigated, and appropriate action will be taken.

9. Monitoring and Review

We will monitor the effectiveness of our policies and procedures in combatting modern slavery and will review the policy regularly to ensure its continued suitability and effectiveness. Annual reports on our efforts and progress in this area will be published.

10. Consequences of Non-Compliance

Any employee found to be in breach of this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We also expect our suppliers and contractors to adhere to the same standards. Failure to comply may result in the termination of our business relationship.

11. Approval

This policy has been approved by Masters in Mind’s board of directors and is endorsed by senior management.

12. Contact Information

For any questions regarding this policy, please contact info@mastersinminds.ocm

Effective Date: 01/01/2017 Review Date: 01/01/2025