Modern Slavery and Human Trafficking Policy

Effective Date: February 21, 2018 Approved By: Board of Director

1. Policy Statement

360 Virtual Tour Co.  has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all our business dealings and relationships. We are committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

2. Scope and Responsibility

• Who it applies to: All persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, and third-party representatives.

• Ownership: The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations. The HR has primary and day-to-day responsibility for implementing this policy and monitoring its use.

3. Definitions

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as:

• Slavery: Exercising powers of ownership over a person.

• Servitude: The obligation to provide services imposed by coercion.

• Forced and compulsory labour: Work or service exacted from any person under the menace of any penalty.

• Human trafficking: Arranging or facilitating the travel of another person with a view to their exploitation.

4. Due Diligence Processes

To identify and mitigate risk, we undertake the following actions:

• Risk Assessments: We conduct annual risk mapping of our supply chains based on geography, industry sector, and the nature of the labour (e.g., high-risk sectors like construction, agriculture, or manufacturing).

• Supplier Vetting: All new suppliers must complete a Supplier Health Check or Questionnaire confirming their compliance with the Modern Slavery Act 2015.

• Recruitment: We strictly follow UK “Right to Work” checks. We only use reputable recruitment agencies and require them to confirm they follow ethical employment practices.

• Contractual Terms: Our standard terms and conditions include anti-slavery warranties. We reserve the right to terminate contracts if a supplier is found to be in breach of these standards.

5. Training and Awareness

• Mandatory Training: All employees must complete an annual e-learning module on recognizing the signs of modern slavery (e.g., physical signs of abuse, restricted movement, or withheld identity documents).

• Targeted Training: Staff involved in procurement and HR receive advanced training on high-risk sourcing and ethical supply chain management.

6. Reporting Concerns (Whistleblowing)

We encourage the reporting of concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at the earliest possible stage.

• Internal Channel: Employees should notify their manager .

• Whistleblowing Policy: Reports can be made anonymously via hello@360virtualtour.co We aim to encourage openness and will support anyone who raises genuine concerns in good faith, even if they turn out to be mistaken.

7. Performance Indicators (KPIs)

We will use the following KPIs to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

• Completion Rate: [95%+] of staff to complete mandatory modern slavery training.

• Supplier Compliance: [100%] of Tier 1 suppliers to have signed our Anti-Slavery Code of Conduct.

• Audit Results: Number of supplier audits conducted and remediation actions closed.

8. Breach of this Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy.