Modern Slavery Act

Modern Slavery Act Policy

Overview
TealBook is committed to limiting the risk of modern slavery occurring within its business, infiltrating our supply chain, or through other business relationships.
This policy applies to all persons working for or on behalf of TealBook, in any capacity, including employees, directors, officers, agency workers, contractors, consultants and any other third- party representatives.

Purpose
This policy will be used to underpin and inform any statement on slavery and human trafficking that TealBook is required to produce further to the California Transparency in Supply Chains Act and Part 6, Section 54 of the United Kingdom Modern Slavery Act of 2015.

Scope
Modern slavery can take many forms. All forms of modern slavery involve depriving a person of liberty in order to exploit them for commercial or personal gain and amounting to a violation of an individual’s fundamental human rights. The Modern Slavery Act (MSA) 2015 covers four key criminal activities:
● Slavery: where ownership is exercised over an individual
● Servitude: where coercion is used to impose the obligation to provide service
● Forced and compulsory labour: where the threat of force or penalty is used to obtain all
work or service, not voluntarily performed, from an individual
● Child Labour: where underage labour is utilised for the provision of goods or services
● Human trafficking: involves arranging or facilitating the travel of another with a view to
exploiting them

How TealBook seeks to Embed this Anti-Slavery Policy in Practice
TealBook does not purchase goods or services that are risk of supporting modern slavery. However, whenever contracting of services to third parties is used, TealBook will review the services being contracted and the selected subcontractor to identify any such risk and mitigate it.

Breaches of This Policy
A breach of this policy by an employee, director, or officer of TealBook may lead to disciplinary action being taken, up to and including termination of employment.

Responsibilities and Expectations
TealBook employees are responsible for:
● Familiarizing themselves with this policy in its entirety
● Discussing risk areas with appropriate management and formulating strategies to comply
● Cooperating to the fullest extent possible in any investigation into suspected breaches of
this policy or any related processes or procedures

ELT is responsible for:
● Overall responsibility of this policy and for ensuring that TealBook complies with all its legal and ethical obligations.
If any part of this policy is unclear, employees should reach out to HR@tealbook.com

Policy preparation date: January 1, 2024
Policy effective date: January 25, 2024