Modern Slavery Due Diligence Policy

Emar Libya Company for Asphalt Manufacturing and Petroleum Derivatives

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1. Policy Objective

This policy aims to clarify the due diligence mechanisms implemented by Emar Libya Company for Asphalt Manufacturing and Petroleum Derivatives regarding modern slavery within its supply chains. This includes all activities directly or indirectly related to forced labor, human trafficking, child labor, debt bondage, and any other practices that violate human dignity and freedom.

2. Scope of Application

This policy applies to:

• All employees and workers at various administrative levels.
• Partners, suppliers, contractors, and subcontractors.
• All operations and projects conducted locally and internationally.

3. Definition of Modern Slavery

Modern slavery refers to situations where individuals are exploited and cannot refuse or leave due to threats, violence, coercion, deception, or abuse of power. This includes, but is not limited to:

• Forced labor
• Human trafficking
• Debt bondage
• Child labor
• Slavery-like practices (such as servitude)

4. Responsibilities

4.1 Senior Management

Responsible for setting strategic directions and ensuring that the company adheres to legal and ethical standards related to modern slavery.

4.2 Human Resources Department

Responsible for establishing employment policies that prevent exploitation and promote a safe and fair work environment.

4.3 Procurement Department

Responsible for evaluating suppliers and ensuring they comply with labor rights and ethical standards.

4.4 Employees and Contractors

Required to report any suspected case of modern slavery and to cooperate in all internal investigations.

5. Due Diligence Measures

• Conduct regular assessments of supply chains and associated risks.
• Evaluate suppliers and partners using pre-qualification questionnaires and ethical audits.
• Include specific clauses in contracts that require compliance with modern slavery laws.
• Train employees and contractors on identifying signs of forced labor and reporting procedures.

6. Reporting and Monitoring

• A secure and confidential mechanism is provided for reporting any suspicions or violations.
• All reports will be investigated promptly and thoroughly by the designated compliance team.
• Monitoring procedures will be continuously improved based on risk evaluations and lessons learned.

7. Non-Compliance and Consequences

• Non-compliance with this policy may result in disciplinary actions, including contract termination and reporting to relevant authorities.
• The company reserves the right to suspend or cease cooperation with any supplier or partner proven to be involved in modern slavery practices.

8. Policy Review

This policy will be reviewed annually or whenever necessary to ensure its alignment with international standards and local laws.

Approved by: [Name / Position]
Date: [Insert Date]

9. Commitments

The company commits to the following:

• Integrating human rights and modern slavery considerations into all policies and procedures.
• Promoting a culture of transparency and integrity within the company and its supply chains.
• Collaborating with partners, civil society organizations, and governmental bodies to combat modern slavery.

10. Communication and Awareness

• Disseminating this policy to all employees, partners, and relevant stakeholders.
• Conducting awareness sessions and periodic training for employees and suppliers on modern slavery.
• Ensuring that all communication related to this policy is available in appropriate languages and accessible formats.

11. Risk Assessment

The company undertakes the following procedures to identify and assess risks:

• Analyzing the nature of suppliers’ operations and geographic areas.
• Identifying vulnerable groups or sectors that may be exposed to forced labor or human trafficking.
• Reviewing supply chain records, recruitment practices, and labor conditions.

12. Policy Integration

This policy is integrated with other related company policies, including:

• Code of Ethics
• Occupational Health and Safety Policy
• Child Labor Prevention Policy
• Environmental and Social Sustainability Policy

13. Performance Indicators

The company relies on several indicators to measure the effectiveness of this policy, such as:

• Number of reported cases and the results of their investigations
• Number of suppliers subjected to ethical audits
• Number of training sessions conducted and their attendees
• Improvements in risk assessment results over time

14. Policy Endorsement and Publication

This policy is signed and endorsed by the company's top management and is published on the company’s website and communication platforms to ensure it is accessible to all.