Modern slavery is a criminal offence under the Modern Slavery Act 2015 (the “Act”). Modern slavery can occur in various forms, including servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. This document sets out the policy of Anvil Mobile Ltd (“Anvil”) with the aim of the prevention of opportunities for modern slavery to occur within its businesses or supply chain. This policy’s use of the term “modern slavery” has the meaning given in the Act.

At Anvil, we have a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or those of our suppliers.

STEPS FOR THE PREVENTION OF MODERN SLAVERY

We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our suppliers and other business partners. We require our suppliers to hold their own suppliers to the same high standards.

Whilst recognising our statutory obligation to set out the steps we have taken to ensure that modern slavery and human trafficking is not taking place in our supply chains, we acknowledge that we do not control the conduct of individuals and organisations in our supply chains.

RESPONSIBILITY FOR THE POLICY

Ultimate responsibility for the prevention of modern slavery rests with Anvil’s senior management. The Board of Directors of Anvil Mobile Limited has overall responsibility for ensuring this policy and its implementation comply with our legal and ethical obligations. All staff are trained to understand and comply with this policy.

ACTIONS TO REPORT MODERN SLAVERY OR HUMAN TRAFFICKING

Employees are encouraged to raise any concerns about suspected modern slavery associated with Anvil or our suppliers and should do this either to one of the directors or the Operations Manager.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

BREACHES OF THIS POLICY

If an issue is identified with a supplier we will work with them to prepare a corrective action plan and resolve all violations within an agreed upon time period. We reserve the right terminate our relationship with individuals and organisations in our supply chain if they breach this policy.

COMMUNICATION AND AWARENESS OF THIS POLICY

Our zero-tolerance approach to modern slavery is to be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

REVIEW

Following its initial adoption, this Anti-Slavery and Human Trafficking Policy will be reviewed by Anvil’s Board of Directors on a regular basis (at least annually at the end of each financial year and this document updated accordingly) and may be amended from time to time.