Anti-Slavery Policy

Document Version 1.0 — Published July 23, 2023

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Enclave Networks Limited (“the Company”) is committed to preventing and combating slavery and human trafficking in all its forms. This Anti-Slavery Policy (“the Policy”) outlines our zero-tolerance approach to slavery and human trafficking and our commitment to complying with all applicable laws and regulations, including the Modern Slavery Act 2015.

This Policy applies to all employees, directors, officers, contractors, consultants, agents, suppliers, and any other individuals or entities acting on behalf of Enclave Networks Limited.

1. Prohibited Conduct

   1. Slavery and Human Trafficking: The Company strictly prohibits all forms of slavery, forced labor, human trafficking, and any practices that exploit individuals for labor or services.

   2. Supply Chains: The Company is committed to ensuring that its supply chains are free from slavery and human trafficking. We expect our suppliers and business partners to adhere to the same principles and comply with applicable laws and regulations.

2. Compliance with Laws and Regulations

   1. The Company and its employees will comply with all applicable laws and regulations relating to modern slavery and human trafficking, including the UK Modern Slavery Act 2015.

   2. It is the responsibility of all employees to familiarize themselves with the laws and regulations pertaining to modern slavery and human trafficking.

3. Due Diligence

   1. The Company will conduct due diligence to identify and assess potential risks of slavery and human trafficking within its operations and supply chains.

   2. The Company will take appropriate actions to address any identified risks, including reviewing and selecting suppliers and business partners based on their commitment to ethical practices and compliance with anti-slavery standards.

4. Supplier Engagement

   1. The Company will work closely with suppliers to ensure their understanding and commitment to combatting modern slavery.

   2. Supplier contracts will include provisions that require adherence to anti-slavery principles, and the Company reserves the right to terminate relationships with non-compliant suppliers.

5. Reporting and Whistleblowing

   1. The Company encourages the reporting of any suspected or actual cases of modern slavery or human trafficking.

   2. Employees and stakeholders should promptly report any concerns or incidents. Reports should be made directly to the CEO.

   3. The Company will treat all reports with confidentiality and protect whistleblowers against retaliation.

6. Consequences of Non-Compliance

   1. Violation of this Policy may result in disciplinary action, up to and including termination of employment or contract termination, in accordance with the Company’s disciplinary procedures.

   2. Non-compliance with anti-slavery laws and regulations may result in legal consequences, including fines and imprisonment.