Modern Slavery Policy

Thackeray Modern Slavery Policy
Effective Date: Last Updated:

At Thackeray Mines & Minerals Inc. ("Thackeray", "we," "us," or "our") we are committed to upholding the highest ethical standards in our operations and supply chains. This policy outlines our commitment to preventing modern slavery, human trafficking, forced labour, and other forms of exploitation as defined under international and Canadian laws, including the Modern Slavery Act 2018 (UK), where applicable, and broader ethical standards.

Purpose of the Policy

The purpose of this policy is to:

  • Demonstrate our commitment to combatting modern slavery and human trafficking
  • Outline the measures we take to identify, prevent, and address risks of modern slavery in our operations and supply chains.
  • Ensure compliance with applicable laws, including any Canadian federal or provincial regulations related to labor practices.

Scope

This policy applies to:

  • All employees, officers, and directors of Thackeray Mines & Minerals Inc.
  • All contractors, suppliers, and third parties working on behalf of Thackeray Mines & Minerals Inc..
  • Operations in Canada and internationally, including supply chains involved in mineral exploration, extraction, and associated services.

Our Commitment

We are committed to:

  • Conducting business with integrity and respect for human rights.
  • Ensuring all workers, whether directly employed or working within our supply chain, are treated fairly and without coercion or exploitation.
  • Taking proactive measures to mitigate the risks of modern slavery and human trafficking.

Risk Management and Due Diligence

Thackeray Mines & Minerals Inc. has implemented a robust framework to identify and address risks of modern slavery within our operations and supply chains. We assess risks of modern slavery at all levels, including:

  • Operational Risks: Reviewing employment practices in Thackeray-owned and operated sites.
  • Supply Chain Risks: Evaluating suppliers and contractors for potential exposure to modern slavery practices.

Training and Awareness

Thackeray Mines & Minerals Inc. is committed to:

  • Providing training to employees and contractors on identifying and preventing modern slavery.
  • Raising awareness across the organization about risks and reporting mechanisms.

Reporting and Accountability

A:- Internal Reporting

Employees and stakeholders are encouraged to report concerns related to modern slavery or unethical labour practices through our confidential Whistleblower Hotline or directly to management.

B:- Investigations

Reports of suspected modern slavery are investigated promptly and thoroughly. Where necessary, we collaborate with relevant authorities to address confirmed instances of exploitation.

C:- Non-Retaliation Policy

Thackeray Mines & Minerals Inc. ensures that whistleblowers or individuals raising concerns in good faith are protected against retaliation.

Continuous Improvement

Thackeray Mines & Minerals Inc. is committed to continuously improving our policies and practices to combat modern slavery. This includes:

  • Regularly reviewing and updating this policy to reflect changes in laws, standards, and our operations.
  • Enhancing monitoring processes and expanding our due diligence procedures.

Governance and Compliance

This policy is overseen by Thackeray's Board of Directors and senior management. Compliance with this policy is mandatory, and failure to comply may result in disciplinary action, legal action or termination of contracts, as applicable.

Policy Review

This Modern Slavery Policy will be reviewed annually to ensure its effectiveness and compliance with legal and ethical standards.

Thackeray Mines & Minerals Inc. stands united against modern slavery, committing to ethical practices and the protection of human rights in all aspects of our operations and supply chains.