Modern Slavery & Human Trafficking Policy

Rildco Ltd (trading as Societe John Kennedy) — IRIS HOUSE, 3rd Floor, 3106 Limassol, Cyprus

Effective: April 2026

1. Introduction

Rildco Ltd (trading as Societe John Kennedy) is committed to preventing modern slavery and human trafficking in all aspects of its business operations and supply chains. We recognise our responsibility to act ethically and with integrity and to implement effective systems and controls to ensure modern slavery is not taking place within our organisation or in any of our business relationships.

2. Scope of Policy

This policy applies to all employees, directors, officers, contractors, consultants, suppliers, and any third parties acting on behalf of Rildco Ltd.

3. Our Commitment

We are committed to:

  • Acting ethically and with transparency in all business dealings
  • Maintaining systems to prevent slavery, servitude, forced labour, and human trafficking
  • Ensuring our supply chains are free from exploitation
  • Complying with applicable laws and regulations relating to modern slavery

4. Risk Assessment and Due Diligence

We assess potential risk areas in our business and supply chains by:

  • Evaluating suppliers and partners before engagement
  • Requesting assurances and compliance statements where appropriate
  • Monitoring higher-risk jurisdictions or industries

5. Supplier Expectations

We expect all suppliers and business partners to:

  • Prohibit forced, bonded, or involuntary labour
  • Ensure fair wages and working conditions
  • Allow freedom of movement and employment
  • Comply with all applicable labour laws
  • Provide evidence of compliance if requested

Failure to meet these standards may result in termination of the business relationship.

6. Reporting Concerns

Employees and third parties are encouraged to report any concerns regarding modern slavery or unethical practices. Reports will be treated confidentially, and no individual will suffer retaliation for raising concerns in good faith.

7. Training and Awareness

We aim to raise awareness among employees about modern slavery risks and indicators, ensuring they understand how to identify and report concerns.

8. Responsibility and Governance

The management of Rildco Ltd has overall responsibility for ensuring this policy is implemented and complied with. Regular reviews will be conducted to ensure effectiveness.

9. Continuous Improvement

We are committed to continuously improving our practices to combat modern slavery and will review this policy periodically.

10. Approval

This policy has been approved by the management of Rildco Ltd and is effective as of April 2026.