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 people. 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.'

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.'

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/herself voluntarily.'

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.'

The worst forms of child labour are defined by article 3 of ILO Convention No. 182 as:

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  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;

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

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  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; and

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  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.

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.

Legal and Policy Framework

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

International Standards

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  OHCHR Slavery Convention 1926

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  ILO Convention 29 on Forced Labour 1930

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  ILO Protocol 29 on Forced Labour 2014

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  ILO Convention 138 on Minimum Age 1973

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  ILO Convention 182 on the Worst Forms of Child Labour 1999

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  UN Guiding Principles on Business and Human Rights (UNGPs)

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  GRI Standards 408 (Child Labour) and 409 (Forced or Compulsory Labour)

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  ISO 26000 – Guidance on Social Responsibility

Jurisdictional Legislation

Mejuri's global operations and turnover trigger mandatory modern slavery reporting obligations across four jurisdictions. The table below summarises the applicable legislation and key requirements.

Internal Policies

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  Mejuri’s Supplier Code of Conduct

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  Mejuri's Reporting and Whistleblowing Policy

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  Mejuri's Employee 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 Board approves this policy and Mejuri's annual Modern Slavery Statement(s) and is responsible for signing off on those statements in accordance with applicable legislation (UK Modern Slavery Act 2015, s.54; Australia Modern Slavery Act 2018; Canada S-211).

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 Policy.

SVP, General Counsel — The SVP, General Counsel is responsible for company compliance with applicable laws, including the modern slavery reporting obligations set out in the Legal and Policy Framework section, and for associated training in partnership with other cross-functional stakeholders.

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 Reporting and 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.

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. Mejuri 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 our risk analysis, Mejuri has implemented a series of risk mitigation measures including:

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  engaging in thorough due diligence in the onboarding of all suppliers;

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  assessing suppliers for adherence with Mejuri's Supplier Code of Conduct;

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  communicating Mejuri's strict standards and zero-tolerance approach to forced labour, bonded labour, child labour, and human trafficking;

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  supply chain mapping to identify and address exposure in upstream tiers;

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  periodic announced and unannounced audits of higher-risk suppliers; and

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  maintaining supply chain traceability to verify the origin of goods and identify any exposure under the US Uyghur Forced Labor Prevention Act (UFLPA).

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 annual Modern Slavery Statement(s) and this Modern Slavery and Human Trafficking Policy.

Measuring Effectiveness

Mejuri tracks the following key performance indicators to assess the effectiveness of our actions, which are reported in our annual Modern Slavery Statement(s):

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  Percentage of active suppliers who have completed Mejuri's supplier self-assessment questionnaire

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  Percentage of higher-risk suppliers audited in the reporting period

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  Number of audit findings related to forced or child labour, and the rate of corrective action completion

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  Number of concerns received via the Lighthouse reporting service and resolution timeframes

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  Percentage of employees who have completed modern slavery awareness training

Compliance and Training

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 shall take all reasonable steps to prevent and detect incidences of modern slavery in our operations.

Mejuri provides modern slavery awareness training to all employees during onboarding and on an annual basis through the People Ops team, covering: how to recognise warning signs of modern slavery; obligations under this policy; and how to raise a concern. Employees in roles with direct supply chain responsibility receive additional training tailored to their function.

Non-compliance with this policy will be treated as a serious matter and may result in disciplinary action up to and including dismissal. Where non-compliance involves criminal conduct, Mejuri will cooperate with the relevant authorities.

Grievance Mechanism

This section satisfies the requirements of the Positive Luxury ESG+ 2.0 Butterfly Mark Standard (Social Pillar) and the UN Guiding Principles on Business and Human Rights (UNGPs) effectiveness criteria for non-judicial grievance mechanisms.

In the event of suspected non-compliance with this policy, Mejuri has implemented a reporting 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 outlined in the Legal and Policy Framework section, has been breached, they have a duty to report it. Mejuri has engaged Lighthouse Services as an independent, confidential, third-party grievance and ethics reporting provider. Lighthouse enables anonymous reporting and operates 24 hours a day, 7 days a week.

Report a Concern —

Lighthouse Ethics & Reporting Service

Available 24 hours a day, 7 days a week. Reports may be made anonymously.

Online: www.lighthouse-services.com/mejuri

Toll-free (North America): 1-833-401-0002

Reports may be submitted in any language. All reports are treated as confidential by Lighthouse and are not attributed to the reporter unless the reporter chooses to identify themselves.

Concerns may also be raised directly with a manager or with the SVP, People Operations. Reports received through Lighthouse are triaged and escalated internally to the appropriate team, while preserving the confidentiality of the reporter.

Process and Timeframes

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  Acknowledgement of receipt within 5 business days

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  Initial assessment and triage within 10 business days

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  Investigation completed and outcome communicated to the reporter within 30 days, except in exceptional circumstances

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  Where criminal conduct is suspected, Mejuri will cooperate with the relevant authorities

Non-Retaliation

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. Any person found to have retaliated against a good-faith reporter will be subject to disciplinary action, up to and including termination.

Accessibility

Mejuri is committed to ensuring that this reporting mechanism is accessible to all workers throughout our operations and supply chain. Lighthouse services are available in multiple languages, anonymous reporting is available, and information about how to report concerns is communicated to supply chain workers in relevant local languages where practicable.

Continuous Learning

Aggregate data on grievances received — including volume, category, and resolution outcomes — is reviewed by the VP, Sustainability and reported annually in Mejuri's Modern Slavery Statement(s). Findings inform improvements to due diligence processes, supplier engagement, and training. No personally identifying information is included in these reports.

Grievances and Breaches

In the event of a suspected breach of this policy, and thus a potential infringement of Mejuri's zero-tolerance approach to modern slavery and human trafficking, Mejuri will conduct a thorough and impartial 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. Where a breach is confirmed, Mejuri will assess appropriate remediation for affected workers, which may include safe removal from the situation, access to support services, and/or compensation.

Mejuri ultimately reserves the right to terminate the relationship with any employee, supplier, contractor, or business partner where this is found to be the most appropriate course of action.

Annual Modern Slavery Statements

Mejuri publishes annual Modern Slavery Statements to fulfil its obligations under applicable legislation and to demonstrate continuous improvement, consistent with the requirements of the Positive Luxury ESG+ 2.0 Butterfly Mark Standard. Statements are:

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  approved by the Mejuri Board of Directors;

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  signed by a director in accordance with UK and Canadian requirements;

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  published prominently on Mejuri's website;

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  filed with the relevant government authority where required (Canada — Minister of Public Safety by 31 May; Australia — government register within 6 months of financial year-end); and

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  provided to shareholders alongside financial statements, as required in Canada.

Each annual statement builds on the previous year's statement, evidencing measurable progress against the KPIs set out in the Guidance on Modern Slavery section. The VP, Sustainability co-ordinates preparation and filing of all annual statements.

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. The policy is available at all times on Mejuri's internal HR portal.

This policy is reviewed at least annually and updated to reflect any changes in applicable law, business operations, or best practice. Any questions about this policy should be directed to the VP, Sustainability or People Operations.

Version 2 Updated 2026