Mejuri Modern Slavery and Human Trafficking Policy

Introduction

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Modern slavery is a crime and a violation of fundamental human rights. Globally, modern slavery is thought to affect close to 50 million people1. Human trafficking describes when a person arranges or facilitates the travel of another person with a view to that person being exploited.

The purpose of this policy is to make it explicitly clear that Mejuri Inc. and its affiliates (“Mejuri”) shall prevent and eliminate Modern Slavery and Human Trafficking in its operations, value chain, and in other business relationships.

This policy applies to every individual working for, with, and on behalf of, Mejuri, including all employees, suppliers, contractors, and other business partners.

This policy is not part of Mejuri’s employment contract with any employee, and it may be subject to review and amendment at any time.

Definitions

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Modern slavery is a crime and a violation of fundamental human rights.

Slavery : ‘Slavery, in accordance with the 1926 Slavery Convention, is the status or condition of a person over whom all or any of the powers attaching to the right of ownership are exercised. Since legal ‘ownership’ of a person is not possible, the key element of slavery is the behaviour on the part of the offender as if he/ she did own the person, which deprives the victim of their freedom.’1

Servitude : ‘Servitude is the obligation to provide services that is imposed by the use of coercion and includes the obligation for a ‘serf’ to live on another person’s property and the impossibility of changing his or her condition.’1

Forced or compulsory labour [including bonded labour] : ‘Forced or compulsory labour is defined in international law by the ILO’s Forced Labour Convention 29 and Protocol. It involves coercion, either direct threats of violence or more subtle forms of compulsion. The key elements are that work or service is exacted from any person

under the menace of any penalty and for which the person has not offered him/her self voluntarily.’1

Child labour : ‘Child labour is defined by international standards as children below 12 years working in any economic activities, those aged 12-14 engaged in more than light work, and all children engaged in the worst forms of child labour (ILO).

The term “child labour” is often defined as work that deprives children of their childhood, their potential and their dignity, and that is harmful to physical and mental development. Whether or not particular forms of “work” can be called “child labour” depends on the child’s age, the type and hours of work performed, the conditions under which it is performed, and the objectives pursued by individual countries.’1

‘The worst forms of child labour are very likely to constitute modern slavery. The worst forms of child labour are defined by article 3 of ILO Convention No. 182 as:

• all forms of slavery or practices similar to slavery, such as the sale and trafficking of children, debt bondage and serfdom and forced or compulsory labour, including forced or compulsory recruitment of children for use in armed conflict

• the use, procuring or offering of a child for prostitution, for the production of pornography or for pornographic performances

• the use, procuring or offering of a child for illicit activities, in particular for the production and trafficking of drugs as defined in the relevant international treaties

• work which, by its nature or the circumstances in which it is carried out, is likely to harm the health, safety or morals of children’1

Human trafficking: Human trafficking describes when a person arranges or facilitates the travel of another person with a view to that person being exploited.

‘An offence of human trafficking requires that a person arranges or facilitates the travel of another person with a view to that person being exploited. The offence can be committed even where the victim consents to the travel. This reflects the fact that a victim may be deceived by the promise of a better life or job or may be a child who is influenced to travel by an adult. In addition, the exploitation of the potential victim does not need to have taken place for the offence to be committed. It means that the arranging or facilitating of the movement of the individual was with a view to exploiting them for sexual exploitation or non-sexual exploitation.’1

Legal and Policy Framework

This section highlights the laws, protocols, and conventions guiding this policy as well as relevant internal policies.

UK Modern Slavery Act 2015

OHCHR Slavery Convention 1926

ILO Convention 29 on Forced Labour 1930

ILO Protocol 29 on Forced Labour 2014

ILO Convention 138 on Minimum Age 1973

ILO Convention 182 on the Worst Forms of Child Labour 1999

The California Transparency in Supply Chains Act 2012

Canada’s Modern Slavery Act

Modern Slavery Helpline

Mejuri’s Modern Slavery and Human Trafficking Policy

Mejuri’s Supplier Code of Conduct

Accountability

The Board - The Mejuri Board is responsible for corporate governance and for managing and mitigating significant enterprise risks as they arise in the course of achieving Mejuri’s strategy and corporate objectives.

The Steer Committee - The Steer Committee is responsible for Mejuri’s day-to-day operations and for reviewing and approving all company-level corporate policies.

SVP, People Operations - The SVP, People Operations is responsible for all human resources matters, for developing policies and training that reinforce Mejuri’s core values and for managing and responding to employee and third party concerns that may be escalated through Mejuri’s Reporting and Whistleblowing Policies.

SVP, General Counsel - The SVP, General Counsel is responsible for company compliance with applicable laws and for associated training in partnership with other cross-functional stakeholders.

VP, Sustainability - The VP, Sustainability is responsible for evaluating key third party partners who support Mejuri’s supply chain, for developing Mejuri’s Supplier Code of Conduct and associated frameworks and oversight to support this Modern Slavery and Human Trafficking Policy.

Management - All Mejuri Managers should ensure that their employees are aware of, understand, and comply with all aspects of this Modern Slavery and Human Trafficking Policy.

Employees - All Employees have a personal responsibility for the way in which their conduct impacts human rights, modern slavery, and human trafficking. This personal responsibility extends to ensuring that employees raise any concerns of modern slavery either to their manager or via Mejuri’s Whistleblowing Policy.

Guidance on Modern Slavery

Mejuri strictly prohibits Modern Slavery and Human Trafficking in our direct operations and supply chain. As an organisation, we value integrity, and use this as a guiding principle to champion personal freedom throughout our operations. We shall put in place the necessary systems to ensure that modern slavery is not taking place anywhere within our organisation or in our supply chain.

These systems include a thorough risk assessment of modern slavery in our operations, acknowledging the sector(s) and countries that we work in as an organisation. The Company’s primary modern slavery and human trafficking risks exist within its supply chain, notably in the sourcing of raw materials and product manufacturing, however, the Company has also identified risk in select contractors and suppliers supporting its retail operations, such as cleaning providers. Mejuri shall regularly review modern slavery and human trafficking risks throughout its operations and communicate with and educate key stakeholders to identify and mitigate such risks.

Following the risk analysis, Mejuri has implemented a series of risk mitigation factors including engaging in thorough due diligence in the onboarding of suppliers, assessing suppliers for adherence with Mejuri’s Supplier Code of Conduct, and communicating Mejuri’s strict standards and zero tolerance approach to forced labour, bonded labour, child labour, and human trafficking. Suppliers are regularly reviewed and Mejuri will cease business with any such supplier found to be in violation of this Policy or Mejuri’s Supplier Code of Conduct.

We hold all those we work with to the same zero-tolerance standard towards Modern Slavery and Human Trafficking, including our suppliers, contractors, and business partners. Furthermore, we expect our suppliers to hold their suppliers to the same zero-tolerance standard. Greater detail of how we communicate these expectations clearly to our suppliers can be found in Mejuri’s Supplier Code of Conduct. Ultimately, we shall engage with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.

Mejuri shall continue to be transparent in our approach to ensuring there is no modern slavery or human trafficking in our direct operations, as well as in our supply chain. This is demonstrated through our Supplier Code of Conduct and this Modern Slavery and Human Trafficking Policy.

Compliance

All employees must read this policy in its entirety and comply with it. All those working for us, or on our behalf, are responsible for the successful implementation of this policy, and therefore, shall take all reasonable steps to prevent and detect incidences of modern slavery in our operations.

In the event of suspected non-compliance with this policy, Mejuri has implemented a Whistleblowing procedure available to all direct employees, contracted and temporary personnel, and those working throughout the supply chain.

If any individual involved in Mejuri’s operations suspects that this policy, or any of the supporting policies as outlined in the section titled ‘Legal and Policy Framework,’ has been breached, they have a duty to report it in accordance with Mejuri’s Reporting and Whistleblowing Policies, which enables anonymous reporting through a third party hotline and associated escalation to the SVP, People Operations.

All concerns raised are handled confidentially and addressed within thirty (30) days apart from in exceptional circumstances.

Any individual within Mejuri’s operations who reports concerns of non-compliance in good faith shall not be penalised, and shall not face any detrimental treatment, including the withholding of professional opportunities, disciplinary action, or dismissal.

Grievances and Breaches

In the event of a suspected breach in this policy, and thus a potential infringement on Mejuri’s zero-tolerance approach to modern slavery and human trafficking, Mejuri will conduct a thorough investigation.

This investigation shall include an assessment of the impacts of terminating the professional relationship, as well as whether escalating the breach to the relevant authorities is appropriate.

Mejuri ultimately reserves the right to terminate the relationship with any supplier if this is found to be the most appropriate course of action.

Accessing this Policy

This policy is communicated to employees via the Mejuri Employee Handbook, which is reviewed during employee onboarding and routine training administered by the Mejuri People Ops team.