Modern Slavery Policy

Effective Date: February 2025
Last Reviewed: 05 March 2025
Approved by: Chairman & Group CEO

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1. Introduction

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At Mezzarion, we are committed to eradicating modern slavery, human trafficking, forced labor, and exploitative practices across our operations, supply chains, and investments. As a company focused on sustainable resource development and ethical trade, we uphold the highest human rights and labor standards to ensure that our business activities do not contribute to any form of exploitation.

This policy applies to all Mezzarion subsidiaries, suppliers, business partners, and contractors worldwide. It is aligned with international human rights frameworks, including:

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-The UK Modern Slavery Act 2015
-The Australian Modern Slavery Act 2018
-Canada’s Forced and Child Labour in Supply Chains Act (FLCLA) 2023
-The United Nations Guiding Principles on Business and Human Rights (UNGPs)
-The OECD Due Diligence Guidance for Responsible Business Conduct
-The International Labour Organisation (ILO) Conventions
-The African Charter on Human and Peoples' Rights

Mezzarion believes that profitability and ethical responsibility must go hand in hand, and we remain committed to ensuring that our growth does not come at the cost of human dignity.

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2. Leadership Commitment & Accountability

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Board Oversight: Mezzarion’s Board of Directors oversees the implementation of our modern slavery prevention strategy, ensuring that all business activities comply with international human rights laws.
Executive Sign-Off: This policy is personally endorsed by Eric Nhodza, Chairman & Group CEO, reinforcing top-level accountability.
Annual Reviews & Reports: We review and update this policy annually to strengthen our response to evolving risks.

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3. Risk Assessment & Due Diligence

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Mezzarion conducts comprehensive risk assessments to identify, mitigate, and prevent modern slavery risks in:

• Mining Operations – Ensuring that all mineral extraction activities comply with fair labor laws and ethical employment standards.

• Supply Chains – Vetting suppliers and trade partners to confirm compliance with labor protections, human rights, and anti-exploitation laws.

• Investments & Partnerships – Avoiding financial partnerships with entities engaged in forced labor, child labor, or exploitative employment practices.

• Security & Logistics – Ensuring that third-party contractors (e.g., security providers, transportation firms) meet international labor standards.

Hotspot Analysis: We assess high-risk geographies and industries using Global Slavery Index data, UN reports, and local compliance audits.
Third-Party Audits: We conduct supplier audits through self-assessment questionnaires (SAQs), on-site inspections, and independent verification bodies.
Escalation Protocol: If a supplier or partner is found to violate modern slavery laws, Mezzarion takes corrective action, which may include contract termination and legal consequences.

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4. Supplier Code of Conduct & Compliance

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All Mezzarion suppliers, contractors, and business partners must:

-Comply with all applicable human rights and labor laws.
-Prohibit forced labor, child labor, and exploitative employment practices.
-Pay fair wages, ensure safe working conditions, and provide legal working hours.
-Undergo due diligence checks and participate in audits upon request.
-Report any suspected cases of modern slavery within their supply chain.

Mezzarion reserves the right to suspend or terminate contracts with non-compliant entities.

 

5. Whistleblowing & Grievance Mechanisms

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We provide secure and anonymous channels for employees, suppliers, and third parties to report concerns related to modern slavery or unethical labor practices.

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Confidential Email: info@mezzarion.com

 

Zero Retaliation Policy: All reports are handled confidentially, and whistleblowers are protected from retaliation.
Investigation & Resolution: Each report is thoroughly investigated, and appropriate actions are taken to remedy violations.
Annual Transparency Report: We commit to publishing an annual report summarising modern slavery investigations, remediation efforts, and compliance improvements.

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6. Training & Capacity Building

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Mezzarion provides mandatory training programs for:

-All Employees & Site Workers – Awareness training on modern slavery indicators, ethical labor practices, and reporting mechanisms.
-Procurement & Supply Chain Teams – Ensuring that those involved in supplier selection and contract management are equipped to detect and prevent labor exploitation.
-Senior Leadership & Contractors – Specialised training on human rights laws and ethical business conduct.

 

7. Industry Collaboration & Continuous Improvement

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Mezzarion is committed to working with industry leaders, human rights organizations, and regulatory bodies to strengthen modern slavery prevention. Our partnerships include:

-The Responsible Minerals Initiative (RMI) – Ensuring ethical sourcing of minerals.
-The International Council on Mining and Metals (ICMM) – Promoting responsible mining standards.
-Global Compact & UN Human Rights Working Groups – Engaging in collaborative policy development.
-Regional & Local Partnerships – Supporting African governments and local NGOs in anti-slavery initiatives.

 

Mezzarion commits to:

• Annual policy reviews to align with global best practices.

• Investing in AI and blockchain solutions to enhance supply chain transparency.

• Increasing supplier compliance verification through randomised audits and third-party assessments.

 

8. Conclusion

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At Mezzarion, we take a zero-tolerance approach to modern slavery and are fully committed to ethical business practices, human rights protection, and sustainable supply chains.

 

For further inquiries, collaboration, or reporting concerns, contact:
info@mezzarion.com