Human Trafficking and Slavery

This is Amber (Isle of Man) Limited's human trafficking and anti-slavery statement. This statement was last updated on 4 December 2023.”

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1. What Does this Statement Cover?

This Human Traffic and Slavery Statement (this “Statement”) exists to set out the expectations of Amber (Isle of Man) Limited and our global subsidiaries (“Amber”, “us”, “we”, or “our”) with regard to observing and upholding our zero-tolerance position on human trafficking and slavery

2. Policy Statement

We are committed to conducting our business in an ethical and honest manner and to implementing and enforcing systems that ensure human trafficking and slavery is prevented at all times. Modern slavery is a crime and a violation of fundamental human rights. We recognise that it can take various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

We have a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and expect all companies across the Group to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere within our organisation.

We are also committed to ensuring that there is transparency in our business and that our approach is consistent with our disclosure obligations under all relevant applicable Modern Slavery laws. We expect the same high standards from all of our contractors, suppliers and other business partners, and expect all contractors to operate with specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

3. Who is covered by this Statement?

This Statement sets out the Group expectation, applicable to all Amber employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third-parties), or any of our subsidiaries or their employees, no matter where they are located. This Statement is also applicable to our Officers, Trustees, Board, and/or Committee members at any level.

4. Mitigating Actions

As part of our initiative to identify and mitigate the risk of human trafficking and slavery practices we routinely:

  • Identify and assess potential risk areas in our business and supply chains;
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains;
  • Monitor potential risk areas in our supply chains; and
  • Protect any employee or person reporting any suspicions or knowledge of instances of human trafficking or slavery.
5. How to raise a concern

If you suspect that there is an instance of human trafficking or slavery activities occurring in relation to Amber, you are encouraged to raise your concerns at as early a stage as possible. Please address any concerns to:

Head of Compliance, Amber Gaming

Peveril Buildings, Peveril Square, Douglas, Isle of Man, IM99 1RZ

6. Monitoring and Reviewing

We expect all companies across the Group to adopt control systems and procedures to prevent human trafficking and slavery and to review the same regularly to ensure they are effective in practice.