BAILCAST LTD: MODERN SLAVERY STATEMENT FOR FINANCIAL YEAR ENDED 31st DECEMBER 2022 ISSUED PURSUANT TO SECTION 54 OF THE MODERN SLAVERY ACT 2015

OUR BUSINESS, STRUCTURE AND SUPPLY CHAINS

Bailcast is committed to a work environment that is free from human trafficking¹, forced labour² and unlawful child labour³ (collectively "human trafficking and slavery"). It also strongly believes that it has moral and ethical responsibilities for proactively promoting lawful employment practices.

Bailcast will not knowingly support or deal with any business involved in human trafficking and slavery. It will not knowingly accept commodities, products and/or services from suppliers that employ or utilise child labour³ or forced labour².

This policy statement is Bailcast’s commitment to ensuring that human trafficking and slavery does not exist either within its own business or businesses where it maintains a relationship, especially from within its supply chain.

The Company Directors and Senior Management shall take responsibility for implementing this Policy statement and its objectives and shall provide adequate resources to ensure that human trafficking and slavery is not taking place in the organisation or within its supply chain.

The Policy takes into account and supports the policies and procedures within the Bailcast Business Management System.

All Suppliers are therefore required to adhere to the following:

Requirements:

Will not use forced or compulsory labour, i.e., any work or service that a worker performs involuntarily, under threat of penalty;

Will ensure that the overall terms of employment are voluntary;

Will comply with the minimum age requirements prescribed by applicable laws.

Will compensate its workers with wages and benefits that meet or exceed the legally required minimum and will comply with overtime pay requirements;

Will abide by applicable laws concerning the maximum hours of daily labour;

Will not engage in any practice of slavery, servitude, forced labour, compulsory labour and/or human trafficking outside the UK which would constitute an offence if that conduct took place within the UK; and

Will ensure that any sub-contractors or suppliers from whom they source goods and/or services for incorporation in those supplied to Bailcast, also adhere to these requirements.

Certification:

Suppliers will certify compliance with this Policy and their adherence to relevant human trafficking and slavery laws in each of the relevant countries in which they operate.

Audits:

Upon request, Suppliers must be able to demonstrate compliance with this Policy to the reasonable satisfaction of Bailcast. Bailcast may perform periodic audits on this Policy and Suppliers are expected to fully co-operate with any such audit.

Reporting:

Any breach of this Policy (including by a Supplier) can be reported (in confidence, if required) by contacting Bailcast’s Company Secretary.

Consequences:

Bailcast takes any breach of this Policy extremely seriously.

Suppliers who are found to have or be engaging in human trafficking and slavery or which refuse to co-operate with any audit to verify compliance with this Policy will be liable to have any supply agreement, arrangement or other contract with Bailcast terminated immediately, without compensation.

If a Supplier to Bailcast is found in violation of this policy, Bailcast will take prompt action which may include terminating any supply agreement, arrangement or other contract with that Supplier (as above). It shall also take such remedial steps as the Board of Management shall determine to be necessary to address the violation and seek to prevent its reoccurrence.

This Policy will be reviewed annually.

¹ Human Trafficking: The recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation.

² Forced Labour: All work or service not voluntarily performed and is obtained from an individual under the threat of force or penalty.

³ Unlawful Child Labour: Consists of the employment of children that is economically exploitative, or is likely to be hazardous to, or interfere with, the child's education, or to be harmful to the child's health, or physical, mental, spiritual, moral, or social development.