2.1 What Is Modern Slavery?

Modern slavery is a grave violation of human rights. It refers to situations where individuals are exploited through coercion, threats, or deception and are unable to leave or refuse the situation. Modern slavery deprives victims of their freedom for the commercial or personal gain of others.

Modern slavery encompasses a range of exploitative practices, including:

• Human Trafficking: The recruitment, transportation, or harbouring of people through force, fraud, or deception for the purpose of exploitation.
• Forced Labour: Work or service extracted from a person under threat of penalty and for which the person has not offered themselves voluntarily.
• Debt Bondage: Situations where workers are compelled to work to pay off a debt, often under terms that make the debt impossible to repay.
• Servitude: The obligation to provide services imposed by coercion, where the victim feels they have no realistic choice but to comply.
• Child Labour: Work that deprives children of their childhood, potential, and dignity, and is harmful to their physical or mental development, particularly the worst forms involving hazardous conditions or exploitation.

2.2 Recognising the Warning Signs

Modern slavery can be difficult to detect. Victims may not self-identify due to fear, shame, or lack of awareness of their rights. Indicators that may suggest modern slavery include:

• Workers who appear to be under the control of others and are reluctant to interact
• Workers who do not possess their own identity documents
• Signs that workers are living in degraded or overcrowded accommodation provided by their employer
• Indications that wages are being withheld or that workers are in debt to their employer or a recruitment agent
• Evidence of excessive working hours with little or no rest
• Workers who are unable to freely leave their workplace or who are transported to and from work under supervision
• Signs of physical abuse, malnourishment, or untreated injuries
• Workers who appear fearful, withdrawn, or reluctant to speak about their circumstances

4.1 Risk Assessment

We assess modern slavery risks across our operations and supply chains on an ongoing basis. Our risk assessment considers factors such as geographic location, industry sector, nature of the workforce, and the structure of supply chain relationships.

We recognise that certain aspects of our business may present elevated risks, including:

• Sourcing products from regions with weaker labour protections or higher prevalence of exploitation
• Engaging third-party logistics providers, shipping companies, and port operators in high-risk jurisdictions
• Using labour-intensive services where low-skilled or migrant workers may be vulnerable
• Complex, multi-tier supply chains where visibility into labour practices is limited

4.2 Due Diligence

We conduct due diligence on our supply chains to identify and address modern slavery risks. Our due diligence measures include:

• Assessing new suppliers and business partners before entering into relationships
• Requiring suppliers to acknowledge and commit to our Supplier Code of Conduct
• Seeking information from suppliers about their labour practices and their own supply chain management
• Monitoring for warning signs and red flags in supplier relationships
• Reserving the right to conduct audits or request third-party verification where appropriate

4.3 Contractual Protections

We include modern slavery provisions in our contracts with suppliers and other business partners. These provisions require compliance with applicable laws prohibiting modern slavery, adherence to our Supplier Code of Conduct, cooperation with any investigations or audits, and prompt notification of any known or suspected instances of modern slavery.

Material breach of these provisions may result in termination of the business relationship.

4.4 Training and Awareness

We provide training to relevant Personnel to ensure they understand what modern slavery is, how to recognise warning signs, and what to do if they have concerns. Training is tailored to the roles and responsibilities of different team members, with enhanced training for those in procurement, supply chain management, and compliance functions.

6.1 Obligation to Report

All Personnel must report immediately if they become aware of, or have reasonable grounds to suspect, any instance of modern slavery connected to our business. This includes concerns about our own operations, our suppliers, or any other party in our supply chain.

Early reporting is critical. Even if you are not certain that modern slavery is occurring, it is better to raise a concern that can be investigated than to remain silent.

6.2 How to Report

Concerns may be reported through the following channels:

6.3 Protection from Retaliation

Montage will not tolerate any form of retaliation against individuals who report concerns about modern slavery in good faith. Anyone who believes they have been subjected to retaliation should report this immediately using the channels above or through our Whistleblower Policy.

We encourage transparency and openness. Speaking up about concerns helps protect vulnerable individuals and strengthens our business.

8.1 Oversight

The Chief Executive Officer has overall responsibility for ensuring Montage’s compliance with this Policy and for overseeing our approach to modern slavery. Day-to-day responsibility for implementation rests with the Compliance function, working in collaboration with relevant business units.

8.2 Monitoring and Reporting

We will monitor the effectiveness of our modern slavery prevention measures and seek to improve them over time. Key metrics may include the number of suppliers assessed, training completion rates, concerns reported and investigated, and remedial actions taken.

8.3 Policy Review

This Policy will be reviewed annually to ensure it remains effective and reflects developments in best practice, legal requirements, and our understanding of modern slavery risks. The current version of this Policy is available on our website and upon request.

8.4 Related Policies

This Policy should be read in conjunction with:

• Supplier Code of Conduct
• Whistleblower Policy
• Code of Conduct
• Anti-Bribery and Corruption Policy
• Privacy Policy

Document Information