Introduction

EverWith Inc. (“the Company”) takes a zero-tolerance approach to modern slavery and human trafficking and we are committed to ensuring that our business operates in a socially responsible manner.

The Organisation’s Structure

The Company, and its sister companies EverWith Ltd & FSL, is a supplier of products and services to market sectors that utilise precious metals as a part of their operations, most notably jewellery.  The Company procures products within the UK, Europe and Asia.

Our Policy on Slavery and Human Trafficking

The Company is committed to ensure there is no modern slavery or human trafficking in any part of our business, which includes the supply chain servicing the Company. Our Modern Slavery & Human Trafficking Policy reflects the zero-tolerance we expect of our employees and supply chain partners. This forms part of our overall Code of Conduct, which underpins our commitment to strive for the highest standards of ethics and integrity in all of our business relationships.

This requires the development of effective systems, controls and operating policies to ensure modern slavery and human trafficking does not take place anywhere within transactions and relationships within the Company.

Supply Chains

Our supply chains will consist of the supply of products and services relating to our trade in market sectors relating to precious metals and jewellery, as well as general support services to enable the operation of the business, significant examples would be marketing services, courier and mail services.

Due Diligence Processes

We utilise a number of methods in order to identify and mitigate risks:

• Provide employees with a clearly stated and comprehensive policy on Modern Slavery

• Have systems in place to identify, mitigate and monitor the risk of slavery and/or human trafficking in our supply chains. This may include registration to, or to follow the principles of, particular operating standards or codes of practice. In some cases we may be audited to assess our adherence to various aspects of a particular operating standard.

• To ensure where an issue is identified, there is a robust investigation and if necessary, any rectification is applied to restore adherence to the policy. Included in this is the protection of any whistle blower, where applicable.

Date of Review

This policy has been reviewed and approved by the director on 1st March 2023.

Jonathan Burton

Director, EverWith Ltd