Modern Anti-Slavery Policy

1 Introduction

1.1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain. Cyro have a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chain.

2 Scope

2.2.1 This policy applies to all persons working for Cyro or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, agents, contractors, external consultants, third-party representatives, and business partners.

2.3 Review and Development

2.3.1 This policy or procedure shall be reviewed and updated as necessary by the ISO and, if appropriate, by an auditor external to the Cyro environment to ensure its compliance with any changes to the law, organisational policies, or contractual obligations.

2.3.2 The ISO, by utilising ISO27001 standards, will determine the appropriate levels of security measures applied to any new information systems.

3 Policy

3.1.1 We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain. We expect the same high standards from all our contractors, suppliers and other business partners. As part of our contracting processes, we may include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, and we expect that our suppliers will hold their own suppliers to the same high standards.

3.2 Compliance with the Policy

3.2.1 You must ensure that you read, understand, and comply with this policy.

3.2.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

3.2.3 You must notify your manager or the HR or Legal Department as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.

3.2.4 You are encouraged to raise concerns about any issue of suspicion of modern slavery in any parts of our business or the supply chains of any supplier tier at the earliest possible stage.

3.2.5 If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible.

3.2.6 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chain constitutes any of the various forms of modern slavery, raise it with your manager or the HR or Legal Department.

3.2.7 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment because of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any part of our supply chain. If you believe that you have suffered any such treatment, you should inform your manager immediately.

3.3 Communication

3.3.1 Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

4 Enforcement

4.1.1 Any breach of this policy or procedure by a Cyro user or employee shall be considered a material breach of the policy or procedure and Cyro’s Terms and Conditions. Cyro shall terminate a user’s right to use the Network, withdraw or remove any material uploaded by that user in contravention of this policy or procedure, where appropriate, disclose information to law enforcement agencies and take any legal action against a user for breach of this policy or procedure, including but not limited to claiming all costs, fees, and disbursements (including but not limited to legal fees) connected therewith