Purpose

This Modern Slavery Policy outlines our commitment to combating modern slavery and human trafficking, our responsibilities, and the steps we take to prevent such practices in our operations and supply chains. We have zero tolerance for modern slavery and human trafficking in our business operations, and we expect the same from our direct and indirect supply chains.

Scope

This policy applies to all employees, directors, officers, contractors, and other business partners of Wyrr Inc.

Our Commitment

At Wyrr Inc, we are dedicated to promoting ethical practices and ensuring that our business operations are free from any form of modern slavery. We recognize that preventing these abuses requires proactive measures and ongoing vigilance. Through our zero-tolerance stance, we aim to foster a culture of respect and integrity, ensuring that everyone involved in our operations is treated with dignity and fairness. Together, we can work towards a future free from modern slavery and human trafficking.

Responsibilities

At Wyrr Inc, the responsibility to combat modern slavery and human trafficking is shared across all levels of the organization. We have established clear roles and responsibilities to ensure accountability and effective implementation of our policies.

1. Senior Management
   • Leadership and Commitment : Senior management is responsible for promoting a culture of zero tolerance towards modern slavery and ensuring that our policies are effectively communicated and enforced throughout the organization.
   • Policy Oversight : They oversee the development, implementation, and regular review of this policy.
2. Compliance Team
   • Monitoring and Reporting : The compliance team is tasked with monitoring adherence to our policies, conducting audits, and reporting any incidents or concerns related to modern slavery.
   • Supplier Due Diligence : They lead the due diligence process for partners, assessing compliance with anti-slavery standards and the Act.
3. Human Resources
   • Employee Training : HR is responsible for providing training and resources to employees to raise awareness of modern slavery issues and reporting mechanisms.
   • Support Mechanisms : They ensure that employees have access to support systems for reporting concerns confidentially.
4. All Employees
   • Awareness and Reporting : Every employee is expected to understand our commitment to preventing modern slavery and report any suspected violations or concerns.
   • Upholding Ethical Standards : Employees must adhere to our Code of Conduct and support our efforts to maintain a safe and ethical work environment.

Zero Tolerance

We have a zero-tolerance approach to modern slavery and human trafficking in all our business operations and supply chains. This commitment underscores our dedication to maintaining ethical standards and safeguarding human rights across every aspect of our organization.

Robust Policies

We have developed and maintain robust policies and procedures to prevent modern slavery and human trafficking. These frameworks are designed to ensure ethical practices throughout our organization and supply chains.

Key Principles

• Strict Compliance : All employees as well as partners are expected to comply with our zero-tolerance policy, ensuring that no form of exploitation is tolerated.
• Active Monitoring : We will actively monitor our operations and supply chains to identify and address any potential risks related to modern slavery.
• Clear Accountability : We hold everyone in our organization accountable for upholding this policy. Any breaches will be taken seriously and addressed promptly.
• Support and Reporting : We encourage employees and partners to report any concerns without fear of retaliation, ensuring that all voices are heard.

Due Diligence Processes for Slavery and Human Trafficking

As part of our commitment to identifying, addressing, and mitigating modern slavery, we have established comprehensive due diligence processes. These processes help us identify and assess potential risk areas in our business operations and supply chains, as well as evaluate the effectiveness of our actions. Our key measures include:

• Regular Independent Audits : We engage in regular independent audits and assessments of our supply chains to verify compliance with our policies. These audits provide an objective evaluation of our suppliers' practices and help identify any areas for improvement.
• Accountability for Breaches : We hold the management, employees and partners accountable for any breaches of our policies and the law. Clear consequences are established for non-compliance, reinforcing our commitment to ethical standards.
• Training and Resources : We provide ongoing training and resources to our employees and key stakeholders to raise awareness about modern slavery and human trafficking. This education empowers individuals to recognize signs of exploitation and understand their role in prevention.
• Encouraging Reporting : We actively encourage employees to report any concerns or suspicions regarding modern slavery. Our reporting mechanisms are designed to ensure confidentiality and protect individuals from retaliation, fostering a culture of openness and vigilance.

Through these due diligence processes, we strive to create a responsible and transparent environment that prioritizes the prevention of modern slavery and human trafficking. By continuously assessing risks and promoting accountability, we aim to safeguard human rights throughout our operations and supply chains.

Ongoing Assessment

We are committed to regularly reviewing and updating our policies and procedures to ensure the effectiveness of our processes in assessing and addressing modern slavery and human trafficking risks. Our ongoing assessment includes the following key components :

• Regular Policy Reviews : We conduct systematic reviews of our policies and procedures to ensure they remain relevant and effective in combating modern slavery. Updates are made as needed to reflect changes in legislation, industry standards, and emerging risks.
• Effectiveness Evaluation : We assess the effectiveness of our current processes by analyzing data from audits, employee feedback, and reporting mechanisms. This evaluation informs our continuous improvement efforts and ensures that we are effectively mitigating risks.
• Training Updates : As we update our policies, we also revise our training programs to incorporate new insights and best practices, ensuring that our employees and stakeholders are equipped with the latest knowledge and tools to combat modern slavery.
• Stakeholder Feedback : We seek input from stakeholders, including employees, and community partners, to understand their perspectives and experiences related to modern slavery risks. This feedback is invaluable in refining our approach.

Monitoring and Review

We regularly review and update our policies and practices to ensure they remain effective in preventing modern slavery and human trafficking. Our monitoring and review processes include :

• Supply Chain Monitoring and Auditing : We conduct ongoing monitoring and audits of our supply chains to assess compliance with our anti-slavery policies. This proactive approach allows us to identify any risks or issues and take corrective action as needed.
• Effectiveness of Due Diligence Processes : We regularly review the effectiveness of our due diligence processes to ensure they are comprehensive and responsive to identified risks. This includes analyzing audit results and feedback to refine our assessment methods.
• Training Program Updates : Our training programs and resources are updated as necessary to incorporate the latest insights and best practices. This ensures that our employees and stakeholders are equipped with the knowledge to recognize and address modern slavery risks effectively.

Reporting and Accountability

At Wyrr Inc., we encourage employees, suppliers, and other stakeholders to report any concerns or suspicions regarding modern slavery and human trafficking. We believe that transparency and open communication are vital in addressing these critical issues.

• Reporting Channels : Concerns can be reported confidentially through our dedicated contact: help@wyrr.app . We ensure that all reports are treated with the utmost seriousness and confidentiality.
• Thorough Investigations : We commit to investigating all reports thoroughly and promptly. Our investigation process is designed to ensure fairness and thoroughness, safeguarding the rights of all individuals involved.
• Appropriate Actions : Based on the findings of our investigations, we will take appropriate action. This may include corrective measures within the organization or working with law enforcement and other relevant authorities when necessary.

Conclusion

Wyrr Inc. is committed to acting ethically and with integrity in all our business dealings. We expect our employees, suppliers, and business partners to uphold these principles to ensure that modern slavery and human trafficking have no place in our operations or supply chains. This Modern Slavery Statement reflects our unwavering commitment to combating modern slavery and human trafficking in all its forms.

We recognize that this effort is ongoing, and we are dedicated to continuously improving our practices and raising awareness about these critical issues. Together, we can create a safer and more ethical environment for all individuals involved in our business and supply chains.