Anti-Modern Slavery and Human Trafficking Policy

Version: 1.0
Date: July 18th, 2026

1.Purpose and Scope
This Anti-Modern Slavery and Human Trafficking Policy (the “Policy”) sets out the approach of Jeen to ethical sourcing and the prevention of worker exploitation. This includes the identification and prevention of modern slavery and human trafficking within both our own business operations and our global supply chain. Jeen is committed to conducting business ethically and transparently. This Policy is subject to amendment at any time. 

2. Definitions: Modern Slavery and Human Trafficking
Jeen recognizes that modern slavery and human trafficking are criminal offences and violations of fundamental human rights. 

• Modern Slavery: This term refers to all types of slavery and servitude, including forced or compulsory labor, debt bondage, indentured servitude, and child labor. Our use of the term “modern slavery” reflects the language used in legislation in Australia and the United Kingdom, as well as other international standards. Jeen acknowledges the special sensitivity of the term “slavery” and the ongoing impact of historical slavery on specific communities. We acknowledge and respect these sensitivities without reservation and are committed to playing our part to ensure these deeply wrong and offensive practices are never part of Jeen’s business operations today. 
• Human Trafficking: This refers to the recruitment, transportation, transfer, harboring, or receipt of persons for the purpose of exploitation, including modern slavery. This involves the use of threat or force, coercion, abduction, fraud, deception, abuse of power or vulnerability, or the giving of payments or other benefits to achieve exploitation. 

3. Applicability and Compliance
This Policy applies to all persons working for Jeen and its subsidiaries and affiliates (collectively, the “Jeen Group”). This includes: 

• Directors 
• Officers 
• Employees of Jeen Group entities
  
  All Jeen Group directors, officers, and employees are required to read, understand, and comply with this Policy. The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all personnel, regardless of their role. 

4. Strategic Approach to Modern Slavery
Jeen maintains a zero-tolerance approach toward modern slavery and human trafficking. We are committed to adhering to all laws relevant to countering these practices that apply to the Jeen Group’s business.
Consequences of Non-Compliance
Failure to comply with this Policy can result in: 

• Legal Liabilities: The organization may incur legal liabilities and potential criminal or civil penalties. 
• Reputational Damage: Significant harm to the business and its standing. 
• Individual Liability: Potential legal and professional consequences for individual directors, officers, and employees who are directly involved in misconduct or who choose to ignore the known or suspected misconduct of others. 
• Termination of Relationships: In line with our zero-tolerance stance, Jeen may terminate business relationships with suppliers or third-party partners who fail to comply with the standards set out in this Policy and the Supplier Code of Conduct.
  
  Reporting Obligations
  Jeen is committed to meeting its legal reporting obligations. In relevant jurisdictions where the Jeen Group operates, the organization will publish annual reports regarding the nature of modern slavery and human trafficking risks within its business or supply chain and the specific steps being taken to mitigate those risks. 

5. Reporting Procedures and Employee Responsibilities

If any Jeen Group director, officer, or employee becomes aware of potential indicators of modern slavery or human trafficking, they must promptly notify the Designated Contact Points.

How to Report
Suspected or actual breaches of this Policy must be reported via: 

• Email: ModernSlaveryInquiry@Jeen.com 
• Whistle-blower Policy: Submit a report in accordance with the Jeen Group Global Whistle-blower Policy.
  
  If you are unsure whether particular facts or circumstances present a risk, you are encouraged to contact a Designated Contact Point for guidance.
  
  Organizational Response
  Jeen will investigate all good-faith reports relating to actual or potential breaches. In the event that modern slavery is identified within our business or supply chain, Jeen’s response will prioritize the welfare and safety of workers. Wherever possible, Jeen will work to remedy breaches and mitigate risks. All personnel are required to cooperate fully in any investigation of an actual or potential breach. 

6. Non-Retaliation and Whistleblower Protection
Jeen is committed to ensuring that no person suffers detrimental treatment as a result of reporting in good faith their suspicion that modern slavery or human trafficking is taking place in any part of the business or global supply chain. Reports may be made anonymously where permitted under the Jeen Group Global Whistle-blower Policy.

Any person who believes they have suffered detrimental treatment for reporting a suspicion should raise the matter with: 

• Their Manager 
• People & Culture (P&C) 
• General Counsel  
• The Whistle-blower Hotline/box 

7. Supplier and Sub-Supplier Expectations
Jeen expects its third-party business partners, including suppliers and sub-suppliers, to adhere to standards similar to those set out in this Policy. For more information about the standards that apply to our partners, please refer to the Supplier Code of Conduct.

Appendix 1: Indicators of Modern Slavery and Human Trafficking

The presence of an indicator does not necessarily mean modern slavery is occurring, but it signifies a risk that merits further consideration and immediate reporting to a Designated Contact Point.

Restricted Freedoms 

• Document Withholding: Workers do not possess their passports, visas, or identity cards because the documents are being held by someone else. 
• Movement and Communication: Workers are unable to leave or communicate with people outside their work environment; movement is restricted or monitored. 
• Dependency: Workers are dependent on their employer for housing, transportation, food, or medical care, or are forced to purchase items from persons connected to their employer. 

Working and Living Conditions 

• Lack of Contracts: Workers have no employment contract or are on short-term contracts. 
• Lack of Agency: Workers do not understand their contract or legal protections and have no ability to negotiate terms. 
• Safety and Training: Workers are unskilled, untrained for their work, or lack appropriate clothing and equipment. 
• Accommodation: Workers live in poor or substandard accommodation or have no choice in where they live. 

Financial Arrangements 

• Underpayment: Workers receive no payment or an amount below the local minimum wage. 
• Debt Bondage: Workers are disciplined through fines, have deductions from earnings, or are “bonded” by debt to their employer. 
• Recruitment Fees: Workers are responsible for reimbursing recruitment fees improperly imposed upon them (such as by recruitment agencies). 
• Unwanted Services: Workers are charged by their employer for services they do not want or need. 

Behaviour and Appearance 

• Communication: Allowing others to speak for them even when addressed directly, or speaking as though instructed by someone else. 
• Demeanor: Appearing fearful, anxious, or distrustful of authorities (e.g., afraid of losing immigration status). 
• Physical Signs: Suffering from injuries that appear to be the result of assault or control measures. 

Geographic Risks 

Workers may be working in a country that: 

• Is recognized to have a high prevalence of human rights violations, including modern slavery and human trafficking (countries ranked 1 to 60 on the Global Slavery Index 2023). 
• Has inadequate protections for workers, including limited capacity or inclination to monitor and enforce compliance with workplace standards. 
• Forces parts of the population to work for development purposes (e.g., compulsory construction or agriculture projects). 
• Has a high prevalence of vulnerable people who are impoverished, displaced (due to conflict or natural disaster), or subject to severe discrimination. 

Product and Service Risks 

Heightened risks exist where cost requirements or delivery timeframes are excessive. High-risk items and sectors include: 

• Products: Electronics, lithium-ion batteries, silica-based products, food products (e.g., cocoa/chocolate), textiles (e.g., cotton), coal, rubber, timber, gold, cobalt, or diamonds. 
• Sectors: Facilities management (cleaning), logistics, and security. 

Entity Risks 

• Compliance History: Entities previously reported as noncompliant with human rights or labor standards by media, international organizations, or NGOs. 
• Opaque Supply Chains: Poorly managed sourcing processes or complex chains that lack oversight of sub-suppliers. 
• Unreliable Audits: Audit results that appear unreliable or conflict with other information sources. 

Appendix 2: High-Prevalence Countries (Global Slavery Index 2023) 

The following 60 countries are identified as having a higher prevalence of modern slavery.