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Policy as of 15th September 2022 (Financial Year Ending 31 August 2023)

Optimise Media Group Limited (Optimise) recognises its obligations under the Modern Slavery Act 2015 and is committed to ensuring that there is no occurrence of modern slavery or human trafficking within its business. As part of our overall commitment to operate ethically we have a zero-tolerance policy where any such occurrence is concerned.

Optimise is a parent company within a group that operates within the digital advertising industry with multiple office locations spanning different countries. Our relevant businesses are:

Our core supply chain is by and large limited to other businesses that operate within the digital advertising industry and includes technical service providers, online publishers, advertisers (brands) and advertising/media agencies. We also use support services such as accountants and legal advisors.

We expect our suppliers to share our own business commitments to principles including:

No use of child, slave or forced labour

Employment is voluntary with ethical terms

Ensuring that employment laws are adhered to including those relating to wages, overtime, working hours, sickness and benefits

We have assessed the risk of non-compliance with the Act to be low. Onboarding new suppliers reflects the risk context and where the risk is considered to be significant, measures will be taken to ensure compliance. This may include verifying supplier commitments within published Modern Slavery Policies and securing compliance commitment within contracts. Staff that are responsible for onboarding of suppliers are informed to assess the risk and carry out appropriate checks where the risk is considered to be significant

We encourage our staff to remain vigilant and report any non-compliance occurrences, risks or concerns to the Optimise senior management team (or directly to the Board of Directors) and we are committed to acting decisively and in good faith to address any such concerns. The Directors of the business will ensure any such issues are investigated and resolved. We have internal disciplinary procedures for dealing with such scenarios and where issues involve our suppliers, we would take appropriate remedial steps.

As part of its commitment to encouraging its staff to report any issues or concerns, Optimise is committed through its whistleblowing policy to protecting staff from negative reprisals as a result of reporting any issue in good faith.

Our policy is reviewed annually in line with our end of financial year (31st August) and is approved by our Board of Directors.

Richard Savelli (CFO)

(Approved 15th September 2022)