IMTC Modern Slavery & Human Trafficking Policy

Introduction

At IMTC, we are deeply committed to combating modern slavery and human trafficking in all their forms. Although our company does not involve traditional supply chains, we recognize the importance of taking proactive measures to prevent and address these crimes within our operations and broader ecosystem. This policy outlines our commitment and approach to ensuring ethical practices and human rights.

1. Commitment to Ethical Practices

IMTC is committed to:

• Upholding the highest ethical standards and respecting human rights in all aspects of our business.
• Complying with all applicable laws and regulations related to modern slavery and human trafficking.
• Adhering to internationally recognized human rights standards, including but limited to the Universal Declaration of Human Rights.

2. Governance & Accountability

Responsibility for overseeing our commitment to combatting modern slavery and human trafficking lies with IMTC’s Senior Management. They are accountable for providing the necessary resources, support, and oversight to ensure the effective implementation of this policy.

3. Risk Assessment & Due Diligence

Although we do not have traditional supply chains, we recognize the importance of assessing potential risks related to modern slavery and human trafficking within our operations. This includes:

• Conducting a thorough risk assessment to identify any areas of vulnerability.
• Assessing the potential risks associated with our business operations, including our workforce, contractors, and partners.
• Implementing appropriate due diligence processes to mitigate identified risks.

4. Employee Training & Awareness

IMTC provides comprehensive training and awareness programs to ensure that all employees understand the risks of modern slavery and human trafficking and their role in preventing it. This includes:

• Training programs for employees at all levels of the organization, emphasizing the importance of ethical behavior and human rights.
• Regular communication and awareness initiatives to keep employees informed and engaged.
• Providing channels for employees to report any concerns or suspicions they may have.

5. Reporting Mechanisms

We encourage the reporting of any concerns or suspicions related to modern slavery and human trafficking. We have:

• Established and maintained clear and confidential reporting mechanisms for employees.
• Any reports will be investigated thoroughly, and appropriate action will be taken in response to any substantiated allegations.

6. Monitoring & Evaluation

We will monitor and evaluate the effectiveness of our efforts to combat modern slavery and human trafficking. This includes:

• Regularly reviewing and updating our policies, procedures, and training programs to ensure they remain effective and relevant.
• Conducting periodic assessments to measure compliance and identify areas for improvement.
• Engaging with external stakeholders, including industry peers and experts, to share knowledge and best practices.

7. Continuous Improvement and Collaboration

We are committed to continuous improvement and collaboration in our efforts to combat modern slavery and human trafficking. This includes:

• Collaborating with our peers and partners to share knowledge, resources, and best practices.
• Supporting certain initiatives that promote ethical practices and respect for human rights in the technology sector.

8. Transparency and Communication

We will maintain transparency and open communication regarding our efforts to combat modern slavery and human trafficking. This includes:

• Making this policy publicly available on IMTC’s website and in other relevant communications materials.
• Engaging with stakeholders, including customers, investors, and NGOs, to address questions, concerns, and feedback.

Conclusion

At IMTC, we are committed to taking decisive action to prevent and address modern slavery and human trafficking, even though we do not have traditional supply chain exposure. This policy reflects our dedication to upholding human rights, ethical practices, and social responsibility within our operations and broader ecosystem.