Policy statement

I. Introduction

II. Definitions

III. Responsibilities

IV. Due Diligence

V. Reporting Violations

VI. Continuous Improvement through Training and Awareness

VII. Reporting and Compliance

VIII. Conclusion

imc is committed to upholding the highest standards of ethical conduct and human rights
throughout our operations and supply chain. We recognise the seriousness of modern slavery
and human trafficking and are dedicated to preventing these abuses in all aspects of our business.
This policy outlines our commitment to compliance with the UK Modern Slavery Act and all other
pertinent legislation, as well as our approach to preventing modern slavery in our operations and
supply chain.

Exploitation: Slavery, servitude or forced or compulsory labour; sexual exploitation including but
not limited to prostitution and sexual offences against children; the removal of organs unless duly
authorised by the competent authorities; the securing of services or other benefits/advantages by
force, threat or deception; and the securing of services by children or physically or mentally ill or
disabled persons, where it is reasonable to expect, that someone would have refused them, but
for their vulnerability.

Human trafficking: The organisation or facilitation of the travel of another person for the purpose
of exploiting that person. It is irrelevant, whether this person has consented to the journey or not.
The exploitation does not have to have actually taken place.

Modern slavery: This includes slavery, servitude, forced and compulsory labour and human
trafficking

Senior Management: Senior management is responsible for overseeing the implementation of
this policy and ensuring compliance with the Modern Slavery Act. They will provide leadership,
resources, and support to promote a culture of transparency and accountability.

Employees: All employees are responsible for familiarising themselves with this policy and
conducting themselves in accordance with its principles. Employees should report any concerns
or suspicions of modern slavery or human trafficking promptly and confidentially to their manager
or the designated point of contact.

Supply Chain Partners: We expect our suppliers, contractors, and business partners to share
our commitment to preventing modern slavery and human trafficking. We will work collaboratively
with them to assess and address risks within our supply chain and promote compliance with the
Modern Slavery Act.

We will conduct due diligence assessments to identify and mitigate the risk of modern slavery
within our operations and supply chain. This includes:

• Assessing the risk of modern slavery in our operations and supply chain, including
  geographical locations and industry sectors.
• Evaluating our suppliers and business partners to ensure they meet our standards for
  ethical conduct and human rights.
• Implementing measures to monitor and address any instances of modern slavery or
  human trafficking identified

In the event of a reasonable suspicion of a breach of this policy, the Compliance Office must be
informed immediately. The Compliance Office can be contacted via the e-mail address set up for
this purpose ([email protected]), the ticket provided for this purpose within the ticket system
or via the contact details listed below. The same applies if a company of the imc Group receives
an official notification concerning an alleged involvement in slavery activities.

Alexandra Razmakhaeva, LL.M.
Legal & Compliance Officer

E-mail: [email protected]; [email protected]