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Modern Slavery Statement

Modern Slavery Statement

Kilwaughter Minerals Ltd acknowledges its responsibilities in relation to ethical business activity and prevention of modern slavery within our supply chain or in any other part of our business.

Modern Slavery encompasses slavery, servitude, forced & compulsory labour and human trafficking. We are committed to acting ethically with vigilance and transparency in all aspects of our business and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

This statement is made pursuant to the Modern Slavery Act 2015 and sets out the steps Kilwaughter Minerals Ltd have taken and are continuing to take to ensure that we, and our supply chain, act in compliance with the Act.

Anti-slavery in practice

Kilwaughter Minerals Ltd are committed to preventing acts of modern slavery and human trafficking from occurring within our business and supply chain.

The creation of our Ethical Sourcing & Trading Policy and Modern Slavery statement was a first step towards the Company having systems in place to:

• Identify and assess potential risk areas in our supply chains

• Mitigate the risk of slavery and human trafficking occurring in our supply chains

• Monitor potential risk areas in our supply chains

A robust vendor evaluation process is conducted on suppliers before they become listed on our approved supplier register. This due diligence includes the antislavery legislation from the Modern Slavery Act ensuring that they confirm that no part of their business operation contradicts this policy.

Kilwaughter Minerals Ltd accepts that it has a responsibility to ensure that employees are not being exploited, are not subjected to poor labour practices, that they are safe and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications. Kilwaughter Minerals Ltd has in place employment contracts and appropriate and relevant company policies to demonstrate its commitment to safe, lawful and ethical standards with its own employees.

Where appropriate, we will engage directly with suppliers in respect of our modern slavery statement in order to gain a proper understanding of the measures they have in place to ensure that modern slavery is not occurring within their own businesses and supply chains.

Questionnaires are sent to new supply chains to ascertain what ethical trading practices they have in place, including a commitment to Social Accountability. This is to be further developed to include a statement specifically requesting a commitment to anti-slavery and human trafficking laws.

Responsibility for this statement

The Chief Executive will have overall responsibility for this statement and for ensuring that the Company complies with all its legal and ethical obligations.

The Supply Chain Manager will have the primary day-to-day responsibility for the implementation of this statement, monitoring its use and ensuring that the appropriate processes and control systems are in place, and amended as appropriate, to ensure it can operate effectively.

All managers are responsible for ensuring that those reporting directly to them comply with the provisions of this statement.

Communication

This statement is published on our website and is communicated with our suppliers and customers as requested.

Breaches of this statement

Any breaches of this statement will be taken seriously and dealt with on a case by case basis.

The breach of this statement by an employee of the company may lead to disciplinary action being taken in accordance with our disciplinary procedure. Serious breaches may be regarded as gross misconduct and may lead to dismissal further to our disciplinary procedure.

Kilwaughter Minerals Ltd may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this statement and/or are found to have been involved in modern slavery. We may also inform the relevant legal bodies to investigate.

Status of this policy

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015.

This statement was approved by the Kilwaughter Minerals Ltd Board of Directors in September 2020.

Signed on behalf of Kilwaughter Minerals Ltd by Gary Wilmot, Chief Executive.