ANTI-SLAVERY AND HUMAN TRAFFICKING POLICY

Introduction

Modern slavery is a fundamental violation of basic human rights and a crime. It takes various forms including slavery, servitude, forced or compulsory labour and human trafficking. These offences are closely related but legally distinct:

1.     slavery is where ownership is exercised over a person;

2.     servitude involves the obligation to provide services imposed by coercion;

3.     forced or compulsory labour involves work or service exacted from any person under the menace of a penalty and for which the person has not offered himself or herself voluntarily; and

4.     human trafficking involves arranging or facilitating the travel of another with a view to exploiting them.

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, labour exploitation including child labour and domestic servitude.

Purpose of the Policy

This Anti-Slavery and Human Trafficking Policy (“Policy”) expresses 3one4 Capital’s commitment to:

1.     act ethically and with integrity in all its business relationships;

2.     ensure that slavery and human trafficking are not taking place in its business or its portfolio companies; and

3.     outline the measures that 3one4 Capital will take to prevent any form of modern slavery in its own business and its portfolio companies.

Application of the Policy

1.     This Policy applies to all officers and directors, employees, workers, contractors, interns, agents, consultants, agency workers and casual workers (“Employees”).

2.     We expect the portfolio companies, vendors and contractors of 3one4 Capital (“Associated Persons”) to observe the same high standards as set out in this Policy; 3one4 Capital endeavours to ensure compliance by such parties.

3.     All Employees are expected to:

a.     read, understand and comply with this Policy; and

b.     raise concerns where there appears to be any contraventions. Please also refer to our Whistleblowing Policy about any suspicion that modern slavery might be occurring in any part of 3one4 Capital’s business or in any of the Associated Persons at the earliest possible opportunity.

Policy statement

1.     3one4 Capital expects all Employees:

a.     to work with 3one4 Capital as it takes these steps;

b.     to remain vigilant in identifying circumstances where there is a risk that modern slavery might be occurring in any part of 3one4 Capital’s business or by any of its Associated Persons;

c.      to report any such circumstances to senior management in full and without delay; and

d.     to conduct their own personal and domestic affairs in such a way to ensure that they are in no way connected with modern slavery either through the commission of a criminal offence or through actions or omissions that might bring themselves and 3one4 Capital into disrepute.

2.     3one4 Capital will seek to ensure, where reasonably practicable and necessary, that the Associated Persons are contractually obliged to comply with terms that reflect the spirit and intention of this Policy in their own businesses and in their own supply chains in support of the general eradication of modern slavery.

3.     3one4 Capital will from time to time, where deemed necessary by 3one4 Capital, assess and review the risk that modern slavery may be occurring in any part of its own business and in any of its Associated Persons. In light of any such risk assessments it may from time to time seek specific reassurances from the Associated Persons; and seek to carry out due diligence or specific audits either itself or through third parties to satisfy itself that modern slavery is not occurring.

4.     3one4 Capital is committed to transparency in its approach to tackling modern slavery.

Responsibility for the Policy

1.     3one4 Capital’s senior management have overall responsibility for this Policy, including ensuring that it complies with legal and ethical obligations.

2.     3one4 Capital wishes to encourage openness and will support anyone who raises a genuine concern that modern slavery might be taking place in any part of the 3one4 Capital’s business or in any of the Associates Persons, even if that concern ultimately turns out to be mistaken.

3.     All Employees are responsible for following the Policy to the extent that it affects their day to-day work and in particular in respect of the reporting requirements.

4.     3one4 Capital 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.

Sanctions

1.     Any breach of this Policy by an Employee including in respect of his or her duties for the 3one4 Capital or in respect of his or her personal and domestic affairs may be dealt with under 3one4 Capital’s disciplinary procedures and may result in dismissal.

2.     If 3one4 Capital has a reasonable belief that modern slavery is occurring in any part of its business:

a.     3one4 Capital will:

                              i.      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

                             ii.      monitor the effectiveness of the remedial action taken including the actions taken to safeguard the victims;

b.     3one4 Capital may, depending on the facts, deal with the matter under its disciplinary procedures which could result in the dismissal of Employee found to be responsible.

3.     If 3one4 Capital has a reasonable belief that modern slavery is occurring in the Associated Persons, 3one4 Capital:

a.     will expect the relevant Associated Person:

                               i.     to be fully transparent and supply such information as 3one4 Capital may reasonably request in relation to the issue;

                              ii.     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;

                             iii.     to monitor the effectiveness of the remedial action taken including the actions taken to safeguard the victims; and

                             iv.     to report to 3one4 Capital 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;

b.     may, depending on the facts and the terms of the contract with the relevant Associated Person, terminate or suspend the relationship or otherwise cease, reduce or minimise business contact with the relevant Associated Person.

Amendments to the Policy

1.     The Policy expresses the will of 3one4 Capital and its commitment to the issues addressed. However, it does not in itself create any contractual obligations and may be amended by the 3one4 Capital at its discretion at any time.

2.     The Policy will be reviewed by the 3one4 Capital on a regular basis.

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