1. Introduction

1.1 Modern-day slavery is a crime and a violation of fundamental human rights. It takes various forms, such as forced labour, sex trafficking, involuntary servitude, and human trafficking, all of which force persons to work against their will in order to exploit them for personal or commercial gain.

1.2 Miniklub Retail Pvt. Ltd. is committed to continually reviewing and improving our efforts to combat slavery and human trafficking.

2. Objective

2.1 The objective of this policy is to define the guidelines on prohibition of Modern Slavery at the Company and in the Supply Chain.

3. Scope of Policy

3.1 This Policy covers the rules and regulations ensuring the business and its supply chains are free from any kind of slavery.

4. Applicability

4.1 These Policy Guidelines shall be applicable to all Units of Miniklub Retail Pvt. Ltd., at all locations currently operational and/or may be set up in the future and in the supply chain.

5. Policy Statement

5.1 We are committed to ensuring that our business operates in a socially responsible way that prevents slavery and human trafficking.

5.2 As soon as the Management is aware of any allegations of human trafficking/slavery activities against any of our current suppliers/vendors, the Management will immediately conduct an appropriate inquiry and report it to the authorities where required.

6. Policy Guidelines

6.1 The Company shall ensure that it does not engage in or support Modern Slavery.

6.2 We set a high bar for ourselves and our suppliers. Our Supply Chain Standards focus on preventing situations that can put workers at risk of modern slavery.

6.3 The Company shall proactively seek to identify and address any potential modern slavery risks and vulnerabilities within it and its supply chain.

6.4 The Company shall ensure that all workers are responsibly sourced and recruited – particularly in the case of vulnerable workers such as seasonal and migrant workers.

6.5 Workers are free to leave their employment within the terms of their contract. All work shall be voluntary, and workers shall be free to leave work and terminate their employment.

6.6 Workers shall have the right to leave the workplace after their shift and shall enjoy freedom of movement.

6.7 The Management requires that Suppliers must not require workers to surrender government-issued identification, passports, or work permits as a condition of work.

6.8 Suppliers must provide workers with documentation clearly stating the terms of employment in a language the worker can understand.

6.9 Due diligence is conducted to ensure the supply of raw material meets our strict policy, and the Organization considers its exposure to slavery/human trafficking to be zero.

6.10 The Management encourages anyone to raise concerns about modern slavery using its whistleblowing policy and will support anyone who acts in good faith.

6.11 In cases where Modern Slavery is found in the workplace or supply chains, the Company shall take appropriate measures to remedy the situation, prioritizing workers' best interests.

6.12 The Management has a zero-tolerance approach to modern-day slavery, ensuring it does not occur in its workplace or supply chain.

6.13 Various policies and programs are instituted to establish our commitment to human rights and ethical behaviour in the workplace.

6.14 Policies and procedures ensure effective systems and controls are implemented to prevent slavery and human trafficking in supply chains.

7. Training and Creating Awareness

7.1 To ensure a high level of understanding of the risks of modern slavery and human trafficking, we conduct training for relevant supply chain members on the benefits they are entitled to and on anti-sexual harassment policies.

7.2 Suppliers are required to train their employees on their rights, including wages, benefits, and grievance redressal forums. Awareness on modern slavery and human trafficking is created for employees managing the supply chain.

8. Exception

8.1 These policy guidelines shall not have any exceptions and shall be guided by the applicable statutory regulations and laws of the Country.

9. Interpretation

9.1 Any matter not specifically covered under the above guidelines shall be referred to Head – HR for necessary advice.

9.2 The interpretation of this policy rests exclusively with the Company. The decision of the Company shall be final and binding.

10. Effective Date

10.1 These guidelines and procedures shall supersede all other earlier guidelines/rules on the subject matter and shall be deemed to have come into force with effect from Nov 01, 2024.

Introduction and Purpose

The Miniklub employees are of great value and the key to our success. Miniklub must strive to provide a workplace where employees can fulfill their potential in an open and inspirational working environment. We must maintain a strong commitment to high standards that deliver a fair, respectable, and safe workplace for all employees in the Group.

The purpose of this policy is to define the labour and human rights standards to which all employees in Miniklub are entitled, irrespective of the country in which they work.

Scope

This policy applies globally to the management, employees, and contract workers of all entities in Miniklub.

Where the Group participates in existing joint ventures as a non-controlling shareholder, the other shareholder(s) shall be made specifically aware of the significance to Miniklub of the policy and shall be encouraged to apply the same policy or a similar standard to the joint venture. For contemplated new minority joint venture cooperation, Miniklub shall strive to commit the other shareholder(s) to adopt the policy or a similar standard for the joint venture.

Requirements

1. Non-Discrimination

1.1 Miniklub does not tolerate any form of discrimination against our employees based on race, color, gender, language, religion, political or other opinion, caste, national or social origin, property, birth, union affiliation, sexual orientation, age, disability, or other distinguishing characteristics.

1.2 Any employment-related decisions, from hiring to termination and retirement, must be based solely on lawful, non-discriminatory criteria.

2. Forced Labour

2.1 Miniklub does not tolerate any form of forced labour, including bonded labour, indentured labour, slave labour, or human trafficking. Workers must be allowed to move around freely and leave their place of work when their working hours end.

3. Child Labour

3.1 Miniklub does not tolerate the hiring of child labour under any circumstances. The minimum age for full-time employment must be 18 or the legal minimum age for employment under Applicable Law, whichever is higher. Where the applicable local minimum working age is 14 in accordance with exceptions for developing countries, this lower age will apply. The Group must not hire employees under the age of 18 for positions requiring hazardous work that could jeopardize health, safety, or morals.

4. Freedom of Association and Collective Bargaining

4.1 Miniklub Group must respect employees’ rights to form, join, or not join a labour union or other organization of their choice, and to bargain collectively in support of their mutual interests without fear of punitive actions such as intimidation, harassment, or termination of employment.

5. Harassment

5.1 Miniklub must protect workers from any acts of physical, verbal, sexual, or psychological harassment, bullying, abuse, or threats in the workplace by either their fellow employees or managers.

6. Working Hours, Benefits, and Wages

6.1 Miniklub must adhere to the stricter of Applicable Laws or industry standards, relating to minimum wages, working hours, overtime, and benefits.

6.2 Employees must not be required to work more than 60 hours a week, including overtime, on a regular basis (or more than the limits on regular hours and overtime allowed by local laws and regulations).

6.3 Wages for overtime must be paid in legal tender on a regular basis. Wage deductions as a disciplinary measure must not be permitted unless provided for by national law. Employees must be entitled to at least one day off in seven, and must be given reasonable breaks while working and sufficient rest periods between shifts.

6.4 Miniklub must be committed to continuously developing employee skills and capabilities, and to providing opportunities for career advancement.

6.5 In the event of major layoffs, Miniklub Retail Pvt. Ltd., as a minimum, must satisfy applicable laws and industry standards.

7. Leave

7.1 Miniklub must ensure that all employees have the right to sick leave and annual holiday, as well as parental leave for employees who have to care for a newborn or newly adopted child as provided by national legislation. Employees who take such leave must not, as a result, face dismissal or threat of dismissal.

8. Employee Contracts/Letters

8.1 All employees must be provided with a written, understandable, and legally binding employment contract/letter.