Gaea Consulting Limited (the “Company”, “we”, “our”, “us”) is dedicated to upholding ethical practices and eliminating all forms of modern slavery, human trafficking, forced labour, and child labour. We recognise the importance of conducting our business responsibly and transparently. This Modern Slavery Policy (the “Policy”) sets forth the Company’s commitment to ensuring our operations and supply chains are free from modern slavery and human rights abuses.

1. Policy Scope

This Policy applies to all employees, contractors, suppliers, and other stakeholders connected to the Company. We expect all such parties to adhere to this Policy and take the necessary steps to prevent any form of modern slavery within their operations.

2. Key Terms and Forms of Modern Slavery

Modern slavery encompasses various forms of exploitation, including:

• Forced labour: The use of coercion, threats, or deception to compel a person to work against their will.

• Child labour: The employment of children under the legal working age, or in work that is hazardous, exploitative, or detrimental to their development.

• Human trafficking: The recruitment, transportation, transfer, harbouring, or receipt of persons through the use of force, coercion, or deception for the purpose of exploitation.

• Debt bondage: A situation in which a person is forced to work to repay a debt, with no control over their working conditions or the terms of repayment.

• Forced Marriage: A situation where individuals are coerced into a marriage arrangement without their genuine consent or against their will, often leading to their exploitation.

3. Company’s responsibilities

• Continuous Risk Assessment: We pledge to continually assess our business operations and supply chains, identifying and addressing potential risks linked to modern slavery.

• Due Diligence Processes: The Company shall establish and maintain stringent due diligence procedures to evaluate our business relations, ensuring our associates uphold our anti-slavery stance.

• Reporting: Channels will be established to facilitate the reporting of concerns or suspicions about modern slavery traces within our operations or supply chains.

4. Due Diligence and Risk Assessment

The Company is committed to implementing due diligence and risk assessment processes in our business and supply chains to identify, assess, and mitigate the risk of modern slavery. We recognise that proactivity is the cornerstone of eliminating modern slavery from our sphere of influence. To this end, we’ve instituted a dual approach that integrates rigorous due diligence with proactive risk assessments, ensuring that our business operations and supply chains remain untainted by such malpractices. Our strategy includes:

• Periodic Evaluations: By systematically conducting risk assessments, we aim to consistently identify and address high-risk zones within our operational framework and broader supply chains.

• Supplier and Contractor Vetting: Prior to formalising any associations, we conduct exhaustive background investigations into potential suppliers and contractors. This not only checks their historical compliance with labour norms but also gauges their commitment to upholding ethical standards.

• Educational Initiatives: We believe in empowering our employees with the knowledge to be our eyes and ears on the ground. Through targeted training sessions and awareness programs, we equip them with tools to recognise, resist, and report instances or risks of modern slavery.

• Monitoring and Accountability: We have set up continuous monitoring protocols and robust reporting mechanisms to ensure that our operations remain compliant not just with our internal guidelines but also with relevant external regulations.

5. Training and Awareness

Understanding the importance of combating modern slavery, we will regularly host training sessions and awareness drives. These initiatives aim to enlighten our employees and stakeholders about modern slavery risks and the procedures to identify, counter, and report suspicious undertakings.

6. Reporting and Escalation

We encourage all employees, contractors, suppliers, and other stakeholders to report any suspicions or evidence of modern slavery or human rights abuses in our operations or supply chains. Reports can be made confidentially to contact@gaea.software without fear of retaliation or reprisal. Confidential channels will be made available for anonymous reporting, and whistleblowers will be assured protection against any form of retaliation.

7. Remedial Actions

In the event that instances of modern slavery or human rights abuses are identified within our operations or supply chains, the Company will take prompt and appropriate action to address the issue. This may include:

• Collaborative Rectification: Instead of unilateral decisions, we believe in a collaborative approach, seeking to engage with our suppliers or contractors. Our goal is to guide and assist them in enhancing their practices, ensuring that the root causes of such malpractices are addressed, preventing future transgressions.

• Contractual Repercussions: While we value our partnerships, non-compliance with our policy and relevant laws will not be tolerated. Contracts with suppliers or contractors found in violation may be subjected to revision or termination, contingent upon the severity and persistence of the breach.

• Legal Disclosures: Upholding transparency and accountability, we commit to reporting any discerned instances of modern slavery to the pertinent authorities, in line with our legal obligations.

8. Continuous Improvement

The Company is committed to continuously improving our practices to combat modern slavery and human trafficking. We will regularly review and update this Policy, as well as our due diligence and risk assessment processes, to ensure they remain effective and aligned with best practices.

This Policy has been approved by the board of directors of the Company and will be reviewed and updated annually.

Date: 21st September 2023