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Modern Slavery Policy

Effective: 12/12/2025 Review: Annually Owner: CEO

Why This Matters

Modern slavery is a fundamental violation of human dignity and rights. Every person deserves to work freely, be treated with respect, and return home safely each day. We will not tolerate any form of slavery, servitude, forced labor, human trafficking, or exploitation in our operations or supply chain. This commitment reflects our core value of treating people as ends in themselves, never as means to our ends.

What We're Committed To

  1. Zero tolerance - We do not use, support, or benefit from any form of modern slavery, including slavery, servitude, forced labor, debt bondage, deceptive recruiting, human trafficking, forced marriage, or child labor
  2. Rio Tinto alignment - We meet or exceed the standards set out in Rio Tinto's Supplier Code of Conduct and Modern Slavery Statement, aligned with the UN Guiding Principles on Business and Human Rights
  3. Freedom and dignity - All workers have freedom of movement, retain their identity documents, receive fair wages for reasonable hours, and can terminate employment with reasonable notice
  4. Supply chain diligence - We conduct risk-based due diligence on our suppliers and business partners, with particular attention to high-risk sectors and geographies
  5. Safe reporting - Workers, contractors, and stakeholders can raise concerns about potential modern slavery through multiple channels without fear of retaliation
  6. Remedy and cooperation - If modern slavery is identified in our operations or supply chain, we will work to provide or enable appropriate remedy for affected individuals

How We Work

Apply professional judgment to assess modern slavery risks in hiring, contracting, and procurement decisions. Watch for warning signs: workers who seem fearful, don't control their own documents, have wages withheld, or work excessive hours. Ask questions when something doesn't feel right. Document your concerns. Your expertise guides the assessment - our standards define what's unacceptable.

When to Escalate

Contact CEO immediately if:

  • You observe or suspect any form of modern slavery or forced labor
  • Workers appear to lack freedom of movement or control of identity documents
  • Recruitment practices seem coercive or deceptive
  • Wage practices appear exploitative
  • You're uncertain whether a situation constitutes modern slavery risk