ANTI-SLAVERY POLICY

MILLION EFFECTS is committed to improving our practice to combat slavery and human trafficking.

We have a zero-tolerance approach to modern slavery and we strive to act ethically and with integrity in all of our business dealings and relationships to ensure that modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We are committed to taking steps to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery Policy reflects our on-going commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in MILLION EFFECTS or our supply chains.

We are committed to assessing the risks of breach of anti-slavery and anti-human trafficking laws and seek to address any issues we find.

As part of our initiative to identify and mitigate risk we ensure that our values and beliefs are embedded within the company at all levels and continue to set guidelines for how we expect our directors, employees and contractorsto behave with each other and other people. We seek to treat everyone fairly and in a consistent manner and foster a workplace that is transparent and built on trust.

We continuously review our systems and processes to:

·  Identify and assess potential risk areas in our supply chains.

This includes looking at the geographies in which they operate and whether they are subject to the same legislative provisions as we are.

·  We are seeking to introduce appropriate contractual provisions in our agreements with the people we do business with.

·  Mitigate the risk of slavery and human trafficking occurring in our supply chains.

·  Monitor potential risk areas in our supply chains.

·  Protect whistle blowers.

We have zero tolerance to slavery and human trafficking.

To ensure all those in our supply chain and contractors comply with our values we are seeking to adopt a compliance programme withinour supply chain.

Forced and child labour are included as risk categories in our supplier risk evaluations and when necessary, we seek to use a third-party firm to assess the potential presence of child labour or forced labour in the supply chain.

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we are committed to training our employees.

We are committed to ensuring new business partners provide training to their employees and suppliers and providers.

We intend to take the following further steps to combat slavery and human trafficking:

·   Include specific provisions in our standard purchasing contracts requiring suppliers to comply with the Modern Slavery Act and commit contractually that neither they nor any other person in their supply chain uses trafficked, bonded, child or forced labour or has attempted to use trafficked, bonded, child or forced labour within their supply chain.

·   Require prospective suppliers in higher-risk industries to provide information about the steps they are taking to eradicate forced labour and human trafficking from their supply chain when bidding to supply goods and services to MILLION EFFECTS.

Modern slavery is a crime and a violation of fundamental human rights.

We expect all staff to ensure that our business is conducted with honesty and integrity.