Modern Slavery and Human Trafficking Policy

Last Updated: 12 November 2024

At Capstone AI ("we", "us", or "our"), we are committed to ensuring that our business and supply chains are free from slavery, human trafficking, and exploitation. This policy outlines our stance on preventing modern slavery and human trafficking within our operations and supply chain.

1. Our Commitment

We are committed to complying with all applicable laws and regulations regarding modern slavery and human trafficking. We maintain a zero-tolerance approach to modern slavery in any form, including forced labor, human trafficking, child labor, and exploitation.

2. Our Business and Supply Chain

Capstone AI operates within the technology and software services industry, and we are committed to ensuring that our operations and the operations of our suppliers, contractors, and partners align with our commitment to eliminating modern slavery and human trafficking. We expect all those in our supply chain to operate with the highest ethical standards and respect for human rights.

3. Policies and Procedures

To mitigate the risk of modern slavery and human trafficking, we have implemented the following measures:

• Due Diligence: We conduct risk assessments of suppliers and third-party partners to ensure compliance with our anti-slavery standards.

• Supplier Code of Conduct: We require our suppliers to adhere to ethical standards that prohibit the use of forced or child labor, human trafficking, or exploitation.

• Employee Training: We provide regular training for employees to recognize and prevent modern slavery and human trafficking in both our operations and the broader supply chain.

• Whistleblowing: We have a confidential whistleblowing policy that allows employees and others to report any concerns about modern slavery or human trafficking within our organization or supply chains.

4. Risk Assessment and Management

We assess the risk of modern slavery in our supply chain by evaluating the industries and countries we operate in, as well as the specific activities of our suppliers. We prioritize high-risk areas for more in-depth assessments, and we work with suppliers to ensure compliance with anti-slavery measures.

5. Supplier Expectations

We expect our suppliers, contractors, and partners to:

• Comply with all relevant laws regarding modern slavery and human trafficking in their respective countries.

• Provide safe working conditions and fair wages.

• Ensure that employees have the right to work freely and voluntarily, without coercion or exploitation.

• Cooperate with Capstone AI’s monitoring processes to ensure adherence to our anti-slavery policy.

6. Employee Responsibilities

Employees are encouraged to report any suspected cases of modern slavery or human trafficking within our operations or supply chains. We take all concerns seriously and will investigate and take appropriate action where necessary. Employees who are found to be involved in modern slavery or human trafficking activities will face disciplinary action, up to and including termination of employment.

7. Monitoring and Auditing

We regularly review our internal practices and the practices of our suppliers to ensure compliance with this policy. This includes conducting internal audits, reviewing risk assessments, and maintaining open communication with our suppliers to ensure continuous improvement in the management of modern slavery risks.

8. Consequences of Non-Compliance

Failure to comply with this policy could result in the termination of relationships with suppliers, contractors, or employees. We will take appropriate action to address any instances of non-compliance and will report violations to the relevant authorities as needed.

9. Review and Updates

This policy will be reviewed annually to ensure its effectiveness and that it reflects any changes in our business operations or legal obligations. We reserve the right to make updates to this policy as necessary.

10. Contact Information

If you have any questions about this policy or need to report concerns regarding modern slavery and human trafficking, please contact us at:

Capstone AI
30 North, Gould Street
Sheridan, Wyoming, 82801
Email: info@capstone-ai.com

Conclusion

At Capstone AI, we are committed to ensuring that slavery and human trafficking have no place in our operations or supply chain. This policy reflects our dedication to ethical business practices and human rights.