Modern Slavery & Human Trafficking Policy

Effective date: May 27, 2026

1. Policy Statement

Salted Stone is committed to conducting its business ethically and with integrity. We have a zero-tolerance approach to modern slavery in all its forms, including forced labor, human trafficking, debt bondage, child labor, and any other form of exploitation.

This policy applies to all persons working for or on behalf of Salted Stone in any capacity, including employees, directors, contractors, consultants, volunteers, interns, and business partners.

2. Scope & Application

This policy applies to Salted Stone and all of its subsidiaries, affiliates, and operations globally. It covers:

• All direct employees and contingent workers
• Contractors, consultants, and freelancers engaged by Salted Stone
• Vendors and third-party service providers
• Business partners and joint venture partners
• Any other party acting on behalf of Salted Stone

3. What Is Modern Slavery?

Modern slavery is a crime and a violation of fundamental human rights. It takes several forms, all of which strip people of their liberty and are exploited for personal or commercial gain. For the purposes of this policy, modern slavery includes:

• Forced or compulsory labor — work performed under threat of penalty where a person has not offered themselves voluntarily
• Human trafficking — the recruitment, transportation, transfer, harboring, or receipt of persons by means of coercion for the purpose of exploitation
• Debt bondage — where a person is forced to work to repay an inflated or fabricated debt
• Child labor — work that deprives children of their childhood, potential, and dignity, and that is harmful to physical and mental development
• Domestic servitude — where individuals are forced to work in private households with restricted freedom
• Sexual exploitation — including forced prostitution or sex trafficking

4. Our Commitments

4.1 Our Own Operations

Salted Stone is committed to ensuring that our own operations are free from modern slavery. We will:

• Verify that all employees have the legal right to work in the relevant jurisdiction
• Pay all workers in accordance with applicable wage laws, modern awards, enterprise agreements, and minimum employment standards in the relevant jurisdiction.
• Ensure all employment contracts are clear, fair, and provided in a language the worker understands
• Not use recruitment fees or other mechanisms that could create debt bondage
• Provide safe and healthy working conditions in compliance with applicable law
• Respect workers' rights to freedom of association and collective bargaining
• Not employ individuals below the applicable minimum working age

4.2 Supply Chain

We are committed to working with vendors who share our values. We will:

• Conduct due diligence on high-risk vendors prior to engagement
• Include anti-slavery and human trafficking clauses in vendor contracts
• Require key vendors to confirm compliance with applicable laws and this policy
• Prioritise vendors who demonstrate transparent and ethical labor practices
• Terminate relationships with vendors who fail to meet our standards and refuse to remediate

5. Due Diligence & Risk Assessment

Salted Stone undertakes ongoing due diligence to identify and manage modern slavery risks in our business and supply chains. Our approach includes:

• Pre-engagement screening of new vendors in higher-risk categories, taking into account geography, sector, and vendor size
• Periodic review of vendor compliance and performance

We recognize that modern slavery risk may be elevated in certain geographies, industries, and types of work. We will focus heightened scrutiny on areas identified as higher risk during our assessment process.

6. Reporting Concerns

All employees and stakeholders are encouraged to raise concerns about any suspected or actual instances of modern slavery, forced labor, or human trafficking — whether in our own operations or our supply chain.

Concerns can be raised through any of the following channels:

• Directly to your line manager or the Business Administration team
• Directly to your Regional Director

Salted Stone prohibits victimisation or adverse action against any person who raises concerns in good faith.. Any employee who engages in retaliation will be subject to disciplinary action up to and including termination.

7. Training & Awareness

Salted Stone is committed to building awareness of modern slavery across our business. Where required by law, training includes:

• Onboarding training for all new employees where legally required covering this policy and how to recognize and report concerns
• Annual refresher training for all staff in roles with supply chain or vendor management responsibility
• Targeted training for People & Culture and Vendor Procurement teams on identifying and responding to modern slavery indicators
• Periodic communications to all staff reinforcing our zero-tolerance commitment

8. Roles & Responsibilities

Responsibility for implementing and maintaining this policy is shared across the organization:

• Leadership Team: Accountable for the overall direction, resourcing, and culture that supports compliance with this policy
• Business Administration: Responsible for employment practices, onboarding, training delivery, and managing internal concerns
• Operations: Responsible for supply chain due diligence, vendor contracts, and monitoring
• All Employees: Responsible for complying with this policy and reporting concerns promptly

9. Monitoring & Review

This policy will be reviewed at least annually, or more frequently if there are significant changes to Salted Stone's operations, supply chains, or applicable legislation. The review will assess the effectiveness of our practices and update our approach based on lessons learned.

Where required by law (for example, under the UK Modern Slavery Act 2015 or equivalent legislation in other jurisdictions), Salted Stone will publish an annual Transparency Statement describing the steps we have taken to address modern slavery risk.

10. Legal Framework

This policy has been developed having regard to applicable laws and international standards, including:

• UK Modern Slavery Act 2015
• Australian Modern Slavery Act 2018
• California Transparency in Supply Chains Act (SB 657)
• ILO Forced Labour Convention (No. 29) and its 2014 Protocol
• UN Guiding Principles on Business and Human Rights
• OECD Guidelines for Multinational Enterprises
• Fair Work Act 2009
• National Employment Standards (NES)
• Applicable Modern Awards and Enterprise Agreements

Where local laws impose additional or different requirements, Salted Stone will comply with those requirements in addition to this policy.

11. Breaches of This Policy

Any breach of this policy by an employee may result in disciplinary action, up to and including termination of employment in accordance with applicable law and company procedures. Any breach by a vendor, contractor, or business partner may result in termination of the commercial relationship and, where applicable, referral to relevant authorities.

Salted Stone reserves the right to audit compliance with this policy at any time, including through independent third-party auditors where appropriate.

Policy Owner: Business Administration

Version: 1.0

Effective Date: May 27, 2026

Next Review: May 2027

Applies to: All employees, contractors, vendors, and partners globally