Modern Slavery and Human Trafficking Policy

Madi Pharmaceuticals
Effective Date: 16 March 2018
Approved by: Board of Directors

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Introduction

Madi Pharmaceuticals is committed to conducting its business with the highest ethical standards and integrity. We recognize the grave impact of modern slavery and human trafficking and are dedicated to identifying, preventing, and mitigating the risk of these abuses across our operations and supply chains.

This policy outlines our commitment to ensuring that all forms of modern slavery, including forced labour, child labour, human trafficking, and debt bondage, have no place in our business practices or supplier relationships.

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Purpose

This policy aims to:

• Establish a clear framework for identifying and addressing the risks of modern slavery and human trafficking.

• Demonstrate our commitment to ethical sourcing and responsible business conduct.

• Communicate expectations to employees, suppliers, contractors, and business partners.

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Scope

This policy applies to all Madi Pharmaceuticals employees, contractors, suppliers, service providers, and business partners, regardless of geographic location or role within the organization.

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Policy Statement

Madi Pharmaceuticals is committed to the following principles:

• Zero Tolerance: We maintain a zero-tolerance approach to all forms of modern slavery in our operations and supply chains.

• Legal Compliance: We comply with all applicable legislation, including Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act and relevant international conventions such as those of the International Labour Organization (ILO).

• Risk Assessment and Due Diligence: We will conduct regular assessments of our suppliers and partners to identify and mitigate risks related to forced or exploitative labour practices.

• Training and Awareness: We will provide training to relevant employees and departments to ensure they understand the risks of modern slavery and how to identify and report potential abuses.

• Reporting and Whistleblower Protection: We offer secure and confidential reporting mechanisms to raise concerns, and we commit to protecting whistleblowers from retaliation.

• Continuous Improvement: We are committed to reviewing and enhancing our policies and procedures to strengthen our ability to prevent modern slavery across our operations.

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Responsibilities

All Madi Pharmaceuticals employees, contractors, and business partners are expected to:

• Read and comply with this policy and any related guidelines.

• Complete required training related to ethical sourcing and human rights.

• Report suspected instances of modern slavery promptly and through the designated reporting channels.

• Support efforts to foster transparent, fair, and ethical working conditions throughout our supply chains.

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Reporting Mechanisms

Any concerns or suspicions about modern slavery or human trafficking must be reported via one of the following channels:

• A line manager or department supervisor

• The Human Resources Department

• Our confidential reporting system at confidentialreport@madipharmaceuticals.ca

We ensure that all reports are treated confidentially and investigated appropriately. No retaliatory action will be taken against individuals who report in good faith.

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Monitoring and Review

Madi Pharmaceuticals will:

• Review this policy annually or as required by changes in legislation.

• Evaluate the effectiveness of our internal controls and supplier due diligence.

• Report on our progress to relevant stakeholders, including through disclosures where required by Canadian law.

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Approval

This policy was reviewed and approved by the Board of Directors of Madi Pharmaceuticals and is in effect as of the date above.