Modern Slavery, Human Trafficking and Child Labour Policy

As part of the global tobacco industry, the Company recognises that it has a responsibility to take a robust approach to slavery, human trafficking and child labour.

The Company is absolutely committed to preventing slavery, human trafficking and child labour in its corporate activities, and to ensuring that its supply chains are free from slavery, human trafficking and child labour.

Organisational structure and supply chains

This statement covers the activities of ATC Worldwide Limited and its subsidiaries.

• Our primary business is procuring, financing, processing, packing, storing and shipping leaf tobacco for sale to manufacturers of tobacco products.

Countries of operation and supply

The Company currently operates in the following countries:

• Brazil, China, India, Indonesia, Malawi, Singapore, South Africa, Thailand, United Kingdom, Zambia and Zimbabwe.

Relevant policies

The Company operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery, human trafficking and child labour in its operations:

• Whistleblowing policy The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
• Employee code of conduct The Company’s code makes clear to employees the actions and behaviour expected of them when representing the Company. The Company strives to maintain the highest standards of employee conduct and ethical behaviour when managing its suppliers.
• Supplier code of conduct The Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The Company works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of the Company’s supplier code of conduct will lead to the termination of the business relationship.
• Recruitment policy The Company uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

 Due diligence

• The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers.
• mapping the supply chain broadly to assess geographical risks of modern slavery, human trafficking and child labour;
• evaluating the modern slavery, human trafficking and child labour risks of any new supplier;
• reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
• taking steps to improve substandard suppliers’ practices, including providing advice to suppliers and requiring them to implement action plans;
• participating in collaborative initiatives focused on human rights in general, and slavery, human trafficking child labour in particular; and
• invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violates our supplier code of conduct, including the termination of the business relationship.

Training

The Company requires all staff working in Brazil, China, India, Indonesia, Malawi, Singapore, South Africa, Thailand, United Kingdom, Zambia and Zimbabwe to complete training on modern slavery, human trafficking and child labour.

The Company’s modern slavery, human trafficking and child labour training covers:

• how to assess the risk of slavery, human trafficking and child labour in relation to various aspects of the business, including resources and support available;
• how to identify the signs of slavery, human trafficking and child labour;
• what initial steps should be taken if slavery, human trafficking or child labour is suspected;
• how to escalate potential slavery, human trafficking or child labour issues to the relevant parties within the Company;
• what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
• what steps the Company should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the Company’s supply chains.