Manandvan Millbank Modern Slavery Statement

Manandvan Millbank is committed to the highest standards of integrity and human rights. This Modern Slavery Statement (also referred to as our anti-slavery statement) sets out the steps we take to prevent slavery, forced labour and human trafficking in our operations and supply chains. We recognise our responsibility to identify and mitigate modern slavery risks, and we adopt a zero-tolerance approach to any form of exploitation.

We maintain a clear, company-wide commitment that slavery and human trafficking are unacceptable. The Millbank modern slavery policy requires all employees, contractors and suppliers to comply with labour standards that protect freedom, fair pay and safe working conditions. Our slavery and human trafficking statement applies across our global operations and to all products and services supplied on our behalf.

Our zero-tolerance policy is enforced through contractual clauses, supplier onboarding checks and employee obligations. We make explicit contractual commitments that vendors must not engage in forced labour, debt bondage, child labour or any other exploitative practice. Breaches of these provisions can lead to termination of contracts and other remedial actions.

We conduct systematic supplier due diligence and regular supplier audits to ensure compliance. Supplier audits include site visits, document reviews, worker interviews and third-party verification where appropriate. Audit findings are categorised by risk level and trigger corrective action plans for remediation. Our approach to supplier audits is risk-based and prioritises high-risk geographies and product categories.

As part of our proactive anti-slavery program, Manandvan Millbank operates a multi-layered compliance framework. Key elements include:

• Risk assessment and mapping of our supply chain;
• Scheduled and unscheduled supplier audits;
• Supplier training and capacity building;
• Corrective action plans and follow-up verification;
• Worker voice mechanisms and grievance procedures.

We expect suppliers to implement their own modern slavery policies and to provide assurance of responsible practices. Our procurement terms incorporate explicit expectations and we require evidence of recruitment practices, working hours, wage records and freedom of movement. Where suppliers supply sub-contractors, they must ensure flow-down of anti-slavery obligations throughout the subcontracting chain.

Reporting Channels and Whistleblowing

How concerns are raised

Manandvan Millbank maintains multiple reporting channels to enable detection and remediation of suspected modern slavery. Employees, suppliers and third parties can raise concerns through internal reporting lines, an anonymous whistleblowing mechanism, or via a designated compliance officer. Reports are treated seriously and investigated promptly and impartially. We protect whistleblowers from retaliation and provide confidentiality to the extent possible during investigations.

Investigation and remediation measures can include on-site follow-up audits, coordination with local authorities or NGOs where necessary, and support to affected individuals. Our response is tailored to the severity and nature of the findings, always aiming to respect the rights and safety of workers while securing compliance with our anti-slavery commitments.