Modern Slavery Policy

Last updated: 17 November 2024

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1. Introduction

Ruffle is committed to preventing modern slavery and human trafficking within its operations and supply chains. This policy outlines our approach to identifying and addressing risks of modern slavery and human trafficking in line with the Modern Slavery Act 2015 (the Act). We expect all of our employees, suppliers, and contractors to share this commitment.

2. Purpose

This policy aims to:

• Set out the Company's stance on modern slavery and human trafficking.
• Detail how the Company will prevent, detect, and respond to modern slavery risks.
• Ensure compliance with the Modern Slavery Act 2015 and other relevant legislation.

3. Definitions

Modern slavery refers to various forms of exploitation, including:

• Slavery: People controlled by force, threats, or coercion.‍
• Servitude: People forced to work against their will, under threat of punishment or abuse
• ‍Forced or Compulsory Labour: People coerced to work through threats or deception.‍
• Human Trafficking: The illegal movement of people, for the purpose of exploitation.

4. Our Commitment

We are committed to:

• Operating ethically and transparently in all business dealings.
• Ensuring there is no modern slavery in our supply chains or in any part of our business.
• Promoting a culture of respect for human rights and dignity for all individuals.
• Complying with the Modern Slavery Act 2015 and other applicable laws.

5. Risk Assessment and Due Diligence

We have implemented systems and processes to assess and address the risks of modern slavery within our business and supply chains:

• Risk Assessment: We regularly assess and monitor our supply chain to identify potential risks of modern slavery.
• Supplier Evaluation: We ensure that our suppliers and partners meet our ethical standards by requiring them to comply with this policy and undergo due diligence procedures.
• Employee Training: We provide regular training to employees to help them identify signs of modern slavery and report concerns.

6. Our Supply Chains

We are committed to ensuring that slavery and human trafficking are not taking place in our supply chains. To this end, we:

• Require suppliers to confirm their compliance with anti-slavery laws and ethical labour standards.
• Use a supplier code of conduct to set clear expectations regarding working conditions, wages, and hours.
• Undertake regular checks and audits to ensure that our suppliers are meeting these standards.

7. Employee and Contractor Obligations

Employees and contractors are expected to:

• Abide by this policy and report any concerns about modern slavery or human trafficking within the Company or its supply chains.
• Participate in training programs designed to raise awareness about modern slavery.
• Cooperate with any investigations into suspected modern slavery.

8. Reporting and Whistleblowing

We have established clear channels for reporting concerns about modern slavery. Employees, suppliers, and contractors are encouraged to report:

• Any suspicion of modern slavery in our supply chains or business practices.
• Any concerns related to the violation of this policy.

Reports can be made confidentially to neil@weareruffle.com, and will be taken seriously and investigated promptly. We will ensure that no one is penalised for reporting concerns in good faith.

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9. Consequences of Non-Compliance

Any employee or business partner found to be in breach of this policy, or involved in modern slavery practices, will be subject to disciplinary action, up to and including termination of employment or business relationships. We will also cooperate fully with law enforcement in cases of suspected criminal activity related to modern slavery.

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10. Review of Policy

This policy will be reviewed annually to ensure its effectiveness and continued compliance with the Modern Slavery Act 2015 and any other relevant regulations. We are committed to making improvements and ensuring the policy remains fit for purpose.

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11. Approval

This policy has been approved by Neil van Ginsburg, and is supported by all levels of the Company.

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Signed:
Nei van Ginsburg
Director
17 November 2024