Modern Slavery Statement

Introduction

Modern slavery is a heinous crime and a morally reprehensible act that deprives a person’s liberty
and dignity for another person’s gain. It is a real problem for millions of people around the world,
including many in developed countries, who are being kept and exploited in various forms of slavery.
Every company is at risk of being involved in this crime through its own operations and its supply
chain.

At Cremarc, we have a zero-tolerance approach to modern slavery and are fully committed to
preventing slavery and human trafficking in our operation and supply chain. We aim to take every
feasible step to ensure modern slavery plays no part in our business, as outlined in our statement.
This statement sets out the actions that we have taken to understand all potential modern slavery
risks related to our business, and to implement steps to prevent slavery and human trafficking in the
future of our business.

Our business and supply chains

We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually
beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the
supplier’s reputation, respect for the law, compliance with health, safety and environmental
standards, and references.

We haven’t been made aware of any allegations of human trafficking/slavery activities against any of
our suppliers, but if we were, then we would act immediately against the supplier and report it to
the authorities.

Risk Assessment

In the past year, we conducted a risk assessment of our supply chain by taking into account:

• The risk profile of individual countries based on the Global Slavery Index
• The business services rendered by the suppliers
• The presence of vulnerable demographic groups
• A news analysis and the insights of labour and human rights groups

This assessment will determine our response and the risk controls that we implement.

Policies

Cremarc operates the following policies for identifying and preventing slavery and human trafficking
in our operations:

• Whistleblowing Policy – we encourage all employees, customers and suppliers to report any
suspicion of slavery or human trafficking without fear of retaliation.

• Code of Conduct – our code encourages employees to do the right thing by clearly stating the
actions and behaviour expected of them when representing the business.

We strive to maintain the highest standards of employee conduct and ethical behaviour when operating
abroad and managing our supply chain.

Supplier due diligence

Cremarc conducts due diligence on all new suppliers during on-boarding and on existing suppliers at
regular intervals. This includes:

• Assessing risks in the provision of particular services

• Auditing the suppliers, and their health and safety standards, labour relations and employee
contracts

We require all suppliers to attest that:

• They don’t use any form of forced, compulsory or slave labour

• Their employees work voluntarily and are entitled to leave work

• They provide each employee with an employment contract that contains a reasonable notice
period for terminating their employment

• They don’t require employees to post a deposit/bond and don’t withhold their salaries for
any reasons

• They don’t require employees to surrender their passports or work permits as a condition of
employment

Awareness

Cremarc continually raises internal awareness of this issue and explaining to our staff:

• Our commitment in the fight against modern slavery
• Red flags for potential cases of slavery or human trafficking
• How employees should report suspicions of modern slavery

 

This statement has been approved by the board of Cremarc Limited at the board meeting on January, 1, 2022 by Gary Coville, CEO.

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