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ANTI-SLAVERY POLICY

Last Updated: September 9, 2025

INTRODUCTION AND STATEMENT OF COMMITMENT

LUMINO STRATEGIES LIMITED ("the Company," "we," "us," or "our") is committed to ensuring that our business operations and supply chains are free from any form of modern slavery, forced labour, servitude, or human trafficking.

We recognize our global responsibility to uphold human rights as defined by the United Nations Guiding Principles on Business and Human Rights, the UK Modern Slavery Act 2015, and relevant European Union Directives, including the Corporate Sustainability Due Diligence Directive (CSDDD).

We operate with a zero-tolerance approach. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

ALIGNMENT WITH INTERNATIONAL STANDARDS

This policy is designed to comply with:

  • The UK Modern Slavery Act 2015 (Section 54).
  • The European Union’s Corporate Sustainability Reporting Directive (CSRD) and CSDDD.
  • Relevant international standards regarding the conduct of contractors and third-party service providers.

OUR BUSINESS AND SUPPLY CHAINS

LUMINO STRATEGIES LIMITED is a digital technology and consultancy company. Our primary business operations include software development, IT consultancy, financial management, and digital infrastructure services.

Our supply chain consists of:

  • Tier 1: Cloud hosting providers, payment gateways, and software infrastructure services.
  • Tier 2: Digital marketing agencies, external content moderation services, and recruitment agencies.
  • Tier 3: General office suppliers and professional services (legal, accounting).

We recognize that while the tech sector is not "high-risk" for manual forced labour, it is exposed to risks regarding the mining of minerals for hardware and the potential exploitation of workers in outsourced digital services.

DUE DILIGENCE PROCESSES

To identify and mitigate risk, LUMINO STRATEGIES LIMITED performs the following due diligence:

  • Audit of Key Suppliers: We review the anti-slavery statements and human rights policies of all major technology partners and financial institutions.
  • Risk Mapping: We identify and assess potential risk areas in our supply chains, particularly regarding outsourced services in jurisdictions with weak labour law enforcement.
  • Onboarding Requirements: All new high-value vendors must verify that they do not use forced or trafficked labour. Contracts include "termination for cause" clauses for human rights violations.
  • Transparent Recruitment: We use only reputable recruitment agencies and verify that all employees and contractors have the legal right to work and are not subject to recruitment fees.

INDUSTRY-SPECIFIC COMMITMENT: ANTI-EXPLOITATION

Given the nature of our digital platforms and services, we extend this policy to the protection of our users. We strictly prohibit the use of our services for:

  • Facilitating human trafficking or any form of coerced services.
  • The exploitation of individuals for the production of non-consensual content.
  • Any forms of personal exploitation or residency schemes.

We employ automated detection tools and manual monitoring to identify patterns associated with trafficking and exploitation. Any verified evidence of such activity will result in an immediate permanent ban and a proactive report to the National Crime Agency (UK) or other relevant international authorities.

ACCOUNTABILITY AND RESPONSIBILITY

The Board of Directors of LUMINO STRATEGIES LIMITED has overall responsibility for ensuring this policy complies with our legal and ethical obligations. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy. We maintain an open-door policy regarding any concerns.

WHISTLEBLOWING AND REPORTING

We encourage the reporting of any suspicion of modern slavery in any part of our business or supply chains. We provide a safe and confidential channel for reporting via:

Email: [email protected]

We guarantee protection for whistleblowers. No employee or contractor will suffer any detrimental treatment (including threats, disciplinary action, or termination) as a result of reporting in good faith their suspicion that modern slavery is or may be taking place.

TRAINING AND AWARENESS

To ensure a high level of understanding of the risks of modern slavery and human trafficking, we provide:

  • Awareness training for our procurement and HR teams.
  • Guidelines for our moderation and support teams on identifying indicators of human trafficking and duress.
  • Communication of this policy to all employees during the onboarding process.

BREACHES OF THIS POLICY

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve the right to terminate our relationship with any third-party supplier or business partner if they breach this policy or fail to take corrective action when a risk is identified.

APPROVAL

This statement has been approved by the Board of Directors of LUMINO STRATEGIES LIMITED and will be reviewed and updated annually.

Last Updated: September 9, 2025