At Transvib JSC, we have a zero-tolerance approach to modern slavery, and are fully committed to preventing slavery and human trafficking in our operation and supply chain. We have taken concrete steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking.

We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier’s reputation, respect for the law, compliance with health, safety and environmental standards, and references.

1. Policies

Transvib JSC operates the following policies for identifying and preventing slavery and human trafficking in our operations:

• Whistleblowing Policy – we encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation.
• Code of Conduct – our code encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.

2. Supplier Due Diligence

Transvib JSC conducts due diligence on all new suppliers during on-boarding and on existing suppliers at regular intervals. This includes:

• Assessing risks in the provision of particular services.
• Auditing the suppliers in line with TAPA and ISO requirements.
• Sanctioning suppliers that fail to improve their performance in line with our requirements.

3. Our Requirement of Suppliers

• They do not use any form of forced, compulsory or slave labour.
• Their employees work voluntarily and are entitled to leave work.
• They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment.
• They do not require employees to post a deposit/bond and do not withhold their salaries for any reasons.
• They do not require employees to surrender their passports or work permits as a condition of employment.

4. Our Recruitment & Employment Principles

We embrace principles supportive of equal treatment without discrimination and with the protection of employment law for all staff. They are broadly based on principles developed by the United Nations and Institute for Human Rights and Business regarding migrant workers. However, we have chosen to extend relevant principles to all our staff. We treat all staff equally; without discrimination and with respect for their human rights. All staff enjoy the protection of relevant UK law in respect of their employment. In particular:

• We bear the full costs of recruitment and do not charge staff fees for hiring, placing or promoting them.
• We provide written statements of terms and conditions of employment to all staff as required by law. These documents explain everything in a clear and transparent way.
• We support the right to seek, obtain and hold employment without discrimination and with complete respect for dignity.
• We do not coerce anyone to work for us. When you choose to work for us, you do so voluntarily.
• You must prove your entitlement to work in the UK. However, we do not hold or retain original passports, identity documents or residency papers. You should retain such documents personally.
• Everyone is paid regularly, in accordance with their terms and conditions. We provide a written summary of pay and deductions (pay slip) on every occasion.
• Everyone has the right to join or not join a trade union at their complete discretion.
• We provide safe and decent working conditions with suitable training as necessary. Our operations comply with or exceed statutory health and safety standards.
• We provide formal grievance provisions through which staff are free to lodge a work-related complaint or raise a matter of concern.
• We do not impede anyone’s freedom of movement or their opportunity to seek employment elsewhere.

5. Our Supply Chain

We also encourage our suppliers to endorse such principles to demonstrate their opposition to human trafficking and modern-day slavery.

6. Respect for Human Rights

Transvib JSC recognizes the importance of maintaining and promoting the fundamental human rights of employees by operating under programs and policies that:

• Promote a workplace free of discrimination and harassment.
• Prohibit child labor, forced labor, and human trafficking.
• Provide fair and equitable wages, benefits, and other conditions of employment in accordance with local laws.
• Provide safe working conditions.
• Recognize employee’s rights to freedom of association.

7. Discrimination and Harassment

We believe every employee has the right to be treated fairly and deserves a comfortable and safe working environment. Transvib JSC prohibits discrimination based on age, race, colour, religion, sex, national origin, marital status, disability, citizenship, sexual orientation, gender identity or expression, military service, or other characteristic protected by law. Everyone has the right to work without fear or intimidation. Transvib JSC does not accept abusive conduct or harassment – a policy made clear from the first day of orientation. Employees are expected to report situations that compromise their ability to do their jobs. Formal channels are available for employees who seek advice or a solution, and our policies strictly prohibit retaliation against employees who express concerns. We manage our business operations so that employees feel they are being treated fairly and respectfully.

8. Diversity and Inclusion

Transvib JSC is committed to be a high-performing organization built on the foundation of a diverse and inclusive workforce, with individuals and teams working to blend a wide range of talents, preferences and perspectives in pursuit of shared purposes. Employees are expected to be open to dialogue and tolerant of others’ differences and participate in open and honest communication as well as assuming the positive intent of others.

9. Forced Labour and Human Trafficking

Transvib JSC will not use slave or involuntary labour, whether bonded, prison, military, compulsory or indentured labour, including debt servitude or human trafficking with respect to any aspect of its operations.

10. Child Labour

Transvib JSC employees will not employ child labour, consistent with the principals relevant to the UK and international laws. Specifically, the Company prohibits the hiring of individuals under the age of fifteen (15) or the local legal minimum working age or the compulsory schooling age, whichever is higher.