CLEVAST MODERN SLAVERY ACT TRANSPARENCY STATEMENT

Introduction

Here at Clevast we are committed to the highest standards of ethics and business integrity in our supply chain. Our dedication to this endeavor ensures working conditions are safe and workers are treated fairly, with respect and dignity. We are committed to ensuring that manufacturing processes are conducted in an environmentally conscious and socially responsible manner.

Clevast does not tolerate modern slavery or human trafficking anywhere in our organization or in our supply chains and is committed to taking all necessary steps to ensure the risk of modern slavery is eliminated as far as possible.

Our statement is made pursuant to California Transparency In Supply Chains Act 2010 ("California Act") and identifies the steps we have taken to ensure slavery and human trafficking does not form part of our supply chains or anywhere within our business.

Our Group and Supply Chain Structure

Our high ethical standards are at the core of how we work as an organization. They play an integral part in guiding decisions and processes in our supply chain. We partner with people and organizations that align with our beliefs and standards. Clevast employs people worldwide and conducts business in countries all around the world.

Our supply chain (where we purchase goods and services) is sourced from countries all over the world. Vendors are carefully vetted to make sure they align with not only our legal and contractual obligations, but also our supplier code of conduct. This code of conduct covers topics such as labor, health and safety, environment, management, and ethics. One of the benefits of having a diverse supply chain is our ability to establish and quickly apply best practices to our suppliers around the world.

Our Policies

Our non-tolerant attitude towards issues such as human trafficking and slavery is confirmed in our company policies that govern our own conduct and that of our suppliers.

Our conduct

Clevast’s Employee Code of Conduct governs the conduct of every Clevast employee in our organization. The Code of Conduct is an agreement where our employees attest their compliance and confirm they carry on business with high ethical standards and in compliance with law.

We have set up a dedicated reporting service in order for employees to anonymously report any potential breaches of the Code of Conduct. This is overseen by our Human Resources group and

our Compliance group who are devoted to analyzing the facts and circumstances provided in any report submitted by an employee and carrying out a thorough investigation.

Our suppliers’ conduct

Our firm stance on eradicating human trafficking and modern slavery is echoed in our implementation and enforcement of a certification requirement for our suppliers. Clevast requires suppliers to certify that any materials incorporated into Clevast products comply with applicable law regarding slavery and human trafficking, child labor, health and safety, working hours and anti-discrimination legislation in every jurisdiction the supplier is carrying on business. This certification requirement is supported and verified by Clevast’s supplier audit process which is described below as well as the mandatory contractual obligations we impose on our suppliers in our standard supplier agreements.

Our Training

Our mandatory training must be completed by all employees annually and is designed to ensure our employees understand their obligations under the Code of Conduct. For employees and managers who work in global supply chain roles, we provide specific training relating to identifying and combatting the risks of modern slavery and human trafficking. Our training is delivered to employees in a diverse range of mediums such as online courses, in-person meetings with management and written resources.

Key Performance Indicators

Social accountability and environmental stewardship in our industry is a key priority for us. This includes understanding the impacts of our decisions and remaining accountable, mindful and responsible. We listen to the needs of not only our customers and employees but our suppliers as well. Since 2020 we have maintained a whistleblower line to encourage all the reporting of all concerns regarding the workplace. All reported concerns are promptly reviewed and investigated.

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