Modern Slavery Statement

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Glowen has taken, and is continuing to take, to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

About Our Company

Our Company is committed to delivering high-quality products and services. We have a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our Policies

We operate several internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

• Modern Slavery Policy.
• Recruitment Policy.
• Code of Conduct.
• Whistleblowing Policy.

Our Suppliers

Our Company maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that particular organization has never been convicted of offenses relating to modern slavery. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff. We also require our business partners to provide training to their staff and suppliers and providers.

Our Performance Indicators

We have reviewed our key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, we are:

• Regularly reviewing our supply chain policy and procedures to ensure our compliance.
• Conducting audits of our suppliers.
• Requiring our staff to complete training on modern slavery.
• Using labor monitoring and payroll systems.