MODERN SLAVERY AND HUMAN
TRAFFICKING POLICY

1.

Introduction
PERSOLKELLY Pte Ltd and its subsidiaries (individually and collectively referred as the “Company”, “We”
or “Us”) have a zero-tolerance policy against all forms of modern slavery, human trafficking, and relatedactivities. We support fundamental human rights for all people, and we expect our employees and otherindividual(s) or organisation(s) that are involved with our business to do the same so as to ensure that ouremployees can be productive and work comfortably. We are committed to complying with applicablemodern slavery laws, statutes, regulations, and codes and to implementing and enforcing effective
systems and controls to ensure no occurrence of modern slavery activities within the workplace. We arecommitted to investigate the risk of slavery and human trafficking occurring in any of our business activities
and carrying out appropriate.

2.

Scope

2.1

This policy applies to all individuals working for us or on our behalf in any capacity and organisations that
we have business dealings with, including employees, officers, directors, agents, volunteers, interns,contractors, sub-contractors, clients, suppliers, and business partners.

2.2This policy does not form part of any employee’s contract of employment or the contract of any worker or
self-employed contractor and we may amend it at any time.

3.

What is Modern Slavery?
Modern slavery is a crime and a violation of fundamental human rights. Modern slavery occurs when an
individual is tricked, coerced, or forced to work whilst being exploited by others, for their personal orcommercial gain. Modern slavery is governed by modern slavery laws. Modern slavery takes many forms,
namely, slavery, servitude, forced labour and human trafficking. Example of these offences are including
but are not limited to the following:•Labour exploitation – This involves forcing a person to work long hours for little or no pay in poor
conditions under verbal or physical threats of violence to the person or the person’s families.

•Domestic servitude - This involves a victim being forced to work in predominantly privatehouseholds, usually performing domestic chores and childcare duties. Their freedom may be
restricted, and they may work long hours often for little or no pay, often sleeping where they work.

Doc Name: MODERN SLAVERY AND HUMAN
TRAFFICKING POLICYThis document is uncontrolled when printed.

Version: 2.0

Issue Date: 4 JUL 2023

Page: 1OWNER: RHQ LEGALMODERN SLAVERY AND HUMAN
TRAFFICKING POLICY

They may be particularly vulnerable to abuses, exploitation, and slavery, as they might be hiddenfrom sight and lack legal protection.
•Forced criminality - This can be understood as the exploitation of a person to commit crimes suchas pick-pocketing, shoplifting, cannabis cultivation, drug trafficking and other similar activities thatare subject to penalties and imply financial gain for the trafficker.

•Sexual exploitation - This includes but is not limited to sexual abuse and forced prostitution.
Victims are forced into sex work or to perform sexual acts against their wishes and without theirconsent.

4.

Prevention of Modern Slavery within the Company and our Supply
Chain
We are committed to acting ethically and with integrity in all our business dealings and relationships andto implementing and enforcing effective system and controls to ensure modern slavery is not taking place
anywhere in our business or in any of our supply chains. We will respect human rights in all our operations
and business dealings.

5.

Compliance with this Policy

5.1

We are committed to the prevention, detection and reporting of modern slavery in any part of our businessor supply chains.

5.2

All employees in the Company are bound by this policy. You must read, understand and comply with thispolicy and you are also required to avoid any activity that might lead to or constitute modern slavery.

5.3

If you believe there is an activity that might lead or constitute modern slavery or if you have knowledge
that a breach of this policy has occurred, you should immediately raise any concerns and report yoursuspicion/breach to your respective Country HR head or Regional HR head or Regional Headquarters
Legal (“RHQ Legal”) or through the whistle-blowing channel at whistleblowing@persolkelly.com. You arealso encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of ourbusiness or supply chains at the earliest possible stage. In the event you are unsure about whether aparticular act, the treatment of workers, or their working conditions within our business or supply chainsconstitutes any of the various forms of modern slavery, you can raise the concerns to your supervisor orRHQ Legal.

Doc Name: MODERN SLAVERY AND HUMAN
TRAFFICKING POLICYThis document is uncontrolled when printed.

Version: 2.0

Issue Date: 4 JUL 2023

Page: 2OWNER: RHQ LEGALMODERN SLAVERY AND HUMAN
TRAFFICKING POLICY

5.4We encourage and practice openness and will support anyone who raises concerns in good faith under
this policy. We are committed to ensuring that no persons will suffer any detrimental treatment as a resultof raising their concerns or reporting their suspicion in good faith in regard to the modern slavery practicethat is or may be taking place in the workplace or in any of our supply chains. Detrimental treatment
includes dismissal, disciplinary action, threats, or other unfavorable treatment connected with raising aconcern.

6.

Breach of this policy
Any suspected breach of this policy by our employees will be investigated and any violation tothis policy will result in disciplinary action, which may lead to termination of employment. In theevent there are any suspicions or concerns that other individual(s) or organization(s) performs amodern slavery activity, we may review/terminate our relationship with such individual(s) andorganization(s) working on our behalf or we have business dealing with, if they are found to be
in breach of this policy.

Doc Name: MODERN SLAVERY AND HUMAN
TRAFFICKING POLICYThis document is uncontrolled when printed.

Version: 2.0

Issue Date: 4 JUL 2023

Page: 3OWNER: RHQ LEGALMODERN SLAVERY AND HUMAN
TRAFFICKING POLICY----------------------This page is intentionally left blank----------------------