Modern Slavery Policy relating to Alpha Terminal

2024 Ionic Information Limited

Introduction

Ionic Information (hereafter known as Ionic) is firmly committed to ensuring that there is no modern slavery or human trafficking in any part of our business or in our supply chains. This policy reflects our commitment to act ethically and with integrity in all our business relationships and to implement and enforce effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our business or in our supply chains. We understand that modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and 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. At Ionic, we have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships.

Scope

This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, wherever in the country they are situated. This policy also applies to all persons involved in the operation of Ionic, including suppliers and business partners.

Policy Statement

Ionic strictly prohibits the use of slavery or human trafficking in our direct operations and in our indirect operations, including our supply chains. We have a zero-tolerance approach to modern slavery and we are committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our business or in any of our supply chains. We are committed to ensuring transparency in our business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.

Due Diligence

Ionic will not knowingly support or deal with any business involved in slavery or human trafficking. We will undertake due diligence when considering taking on new suppliers, and regularly review our existing suppliers. Our due diligence and reviews include:

• Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking.
• Evaluating the modern slavery and human trafficking risks of each new supplier.
• Reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping.
• Conducting supplier audits or assessments, which have a greater degree of focus on slavery and human trafficking where general risks are identified.

We expect all those in our supply chain to comply with our values. The CEO has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Awareness

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we promote awareness among our staff. We also encourage our business partners to raise awareness among their staff, suppliers, and providers. We invest in enhancing our staff's understanding to recognize the risks of modern slavery and human trafficking in our business and supply chains. Through our awareness initiatives, employees are encouraged to identify and report any potential breaches of the organization's anti-slavery and human trafficking policy. Employees are informed about the benefits of stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to eradicate slavery and human trafficking from our business and supply chains.

Reporting

Ionic encourages all its workers, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of, the organization. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. We have a whistleblowing procedure in place and guarantee to protect staff who report concerns from detrimental treatment.

Compliance

Any employee found to be in violation of this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with suppliers, contractors, and other business partners if they breach this policy, or if they are found to have been involved in modern slavery. We will not support or deal with any business knowingly involved in slavery or human trafficking.

Review

This policy will be reviewed as necessary to ensure it remains effective and meets the company's obligations. Any changes will be communicated to all staff. We will continue to enhance our procedures and make them more robust to prevent any slavery or human trafficking activities. We will keep our employees, stakeholders, and other interested parties informed of the steps we are taking to tackle slavery and human trafficking.

This policy has been approved and authorized by:

Richard Parsons
CEO, Ionic Information Ltd
Date: 01/6/23