Anti-Slavery Statement

MODERN SLAVERY ACT 2015

COMPANY STATEMENT

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.

The company has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all business dealings and relationships. We ensure that modern slavery is not taking place anywhere in our business or in any of our supply chains.

We are also committed to ensuring there is transparency in our business and in our approach to tackling modern slavery thought our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.

We expect the same high standards of all our contractors, suppliers, and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labor, 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.

This statement applies to all persons working for Trinetics Group/Just In Time Contract Manufacturing on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, volunteers, interns, agents, contactors, external consultants, third-party representatives, and business partners.

This statement does not form part of any employee’s contract of employment, and we may amend it at any time.

RESPONSIBILITY FOR THE STATEMENT

The Board of Directors has overall responsibility for ensuring this statement complies with our legal and ethical obligations, and that all those under our control comply with it.

The CEO has primary and day-to-day responsibility for implementing this statement, monitoring its use and effectiveness, dealing with queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this statement and are given adequate and regular training on it and the issue of modern slavery in supply chains.

COMPLIANCE

The preventions, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or a under our control. Employees are required to avoid any activity that might lead to, or suggest, a breach of this statement.

Employees must notify their manager or the HR manager as soon as possible if they believe or suspect a conflict with this statement has occurred or may occur in the future.

Employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

If an employee believes of suspects a breach of this statement has occurred or that it may occurred, they must notify their manager or the CEO or report it in accordance with our Whistleblowing Policy as soon as possible.

If employees are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, they should raise it with their manager or the CEO.

The company aims to encourage openness and will support anyone who raises genuine concerns in good faith under this statement, even if they turn out to be mistaken.

We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.

Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavorable treatment connected with raising a concern.

If an employee believes they have suffered any such treatment, they should inform the CEO immediately. If the matter is not remedied, the employee should raise it formally using the procedures which can be found in the company handbook.

COMMUNICATION AND AWARENESS

Training on this statement, and on the risk the business faces from modern slavery in its supply chains, forms a part of the induction process for all individuals who work for the company, and regular training will be provided if necessary.

The company’s zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

BREACHES OF THIS STATEMENT

Any employee who breaches this statement will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

The company may terminate its relationship with other individuals and organizations working on its behalf if they breach this statement.

APPROVAL

The Board of Directors of Stern Brands, Inc. dba Trinetics Group and Just In Time Contract Manufacturing has approved this Modern Slavery Statement.

Sara T. Stern__________________________                            1/1/2023__

Sara T. Stern                                                                                                     Date

CEO

Stern Brands, Inc. dba Trinetics Group and Just In Time Contract Manufacturing