Modern Slavery and Human Trafficking Policy

1. Policy Statement

Mokora is committed to preventing modern slavery and human trafficking in all areas of its business and supply chains. We have a zero-tolerance approach to slavery, servitude, forced or compulsory labour, and human trafficking. We act ethically and with integrity in all our business relationships and implement effective systems and controls to ensure that slavery and human trafficking are not taking place anywhere in our supply chains.

2. Scope

This policy applies to all employees, contractors, suppliers, and business partners of Mokora, regardless of location. It reflects our commitment to acting with integrity and transparency, and to putting effective systems and controls in place to safeguard against modern slavery. As we grow, this policy and the practical actions to enforce it – including training and awareness – will be scaled appropriately.

3. Compliance with Legislation

This policy is aligned with the UK Modern Slavery Act 2015, and Mokora ensures compliance through internal policies, due diligence procedures, and supply chain assessments.

As we operate internationally, we also adhere to local laws that prohibit modern slavery. In South Africa, the Constitution (Section 13 of the Bill of Rights) explicitly prohibits slavery, servitude, and forced or compulsory labour. The Prevention and Combating of Trafficking in Persons Act (2013) criminalises all forms of human trafficking, including forced labour, sexual exploitation, child trafficking, and forced marriage. It also includes provisions for victim protection and enables prosecution both domestically and internationally.

These legal frameworks underpin our commitment to identifying and addressing risks of modern slavery and ensuring that our business practices and supply chains remain ethical and compliant.

4. Responsibilities

Senior management is responsible for ensuring that this policy is implemented and reviewed. All employees and contractors are expected to report concerns and comply with this policy as part of their contractual duty.

5. Due Diligence and Risk Management

Mokora conducts due diligence when onboarding new suppliers and regularly reviews existing suppliers. We evaluate the modern slavery risks of each new supplier and maintain systems to monitor potential risk areas.

6. Training and Awareness

Key staff, particularly those involved in supply chain management and offshore delivery oversight, are trained to understand the risks of modern slavery and how to identify and manage them. Ongoing awareness is promoted through internal communication.

7. Breaches and Enforcement

Any employee who breaches this policy may face disciplinary action, up to and including dismissal. Suppliers found to be in breach of this policy will be subject to review, and contracts may be terminated. Mokora reserves the right to take appropriate legal action in all cases.

8. Review and Monitoring

This policy will be reviewed annually, or as needed, to ensure its effectiveness and relevance. Senior management is responsible for ensuring that any updates are communicated throughout the organisation.