Introduction

Our UK Modern Slavery Act Statement provides information on the steps we have taken to eradicate slavery and human trafficking from our supply chain as well as within our own organization.

The Modern Slavery Act 2015 (the "Act") came into effect on 29 October 2015 and requires those entities carrying on a business or part of a business in the United Kingdom, supplying goods or services, and having annual turnover of £36 million or more, to disclose information regarding the steps they have taken to eradicate slavery and human trafficking from their supply chain as well as within their own organisation during the previous financial year.

We, Gemini Group, (“Gemini”) fully support the UK government’s objectives to eradicate modern slavery and human trafficking and publish this Modern Slavery and Human Trafficking Statement, pursuant to section 54 of the Modern Slavery Act 2015, for the fiscal year ended 31 December 2021.

Gemini is committed to good corporate citizenship and the highest ethical standards. Our approach reflects our commitment to acting ethically and with integrity in all our business relationships, helping to ensure that slavery and human trafficking is not taking place anywhere in our business. We expect all those in our supply chain to adopt a similar approach. To further fulfil these commitments, Gemini has established and maintains systems and controls to safeguard against slavery and related human trafficking in the supply chain of products it purchases from suppliers. Gemini does not manufacture products itself.

OUR VALUES, POLICIES, AND TRAINING

Gemini is committed to sourcing quality products from suppliers who share its ethical values. Our Code of Conduct, provides important guidelines for Gemini's interactions with customers, suppliers and other business partners, and between employees.

There are several principles that are central to the Code of Conduct. All employees are encouraged to raise concerns including potential violations of (i) the Code of Conduct; (ii) company policies and (iii) the laws of the countries in which Gemini operates. Gemini has sophisticated reporting mechanisms in place to collect and relay information regarding potential violations to appropriate company resources for review and follow up.

Gemini has policies which underpin our approach to tackling the risk of modern slavery in our supply chain, including, but not limited to, the whistleblowing provisions set out in the Code of Conduct which encourages employees to raise concerns including potential violations of (i) the Code of Conduct; (ii) company policies; and (iii) the laws of the countries in which Gemini operates. Gemini treats all concerns in good faith.

OUR SUPPLIERS

We have relationships with suppliers and third-party service providers spanning the globe, delivering a wide variety of commodities. Many of these third-party service providers have substantial and diverse supply chains of their own.

We are guided by principles, standards and associated governance structures for effectively identifying, assessing, monitoring, and mitigating risks associated with the use of third-party service providers. We are committed to act ethically and with integrity in our business dealings. To do so, we undergo extensive due diligence reviews of third-party service provider policies relating to, amongst other things, slavery and human trafficking. We expect our third-party service providers to adhere to the same high standards we set for our organization.