FINANCIAL YEAR ENDING December 31, 2023

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and also addresses the California Transparency in Supply Chains Act (2010) and sets out the steps Orveon Global Holdings Limited and its subsidiaries (collectively hereafter “Orveon Global”) have taken and will take to prevent modern slavery and human trafficking in our business operations and supply chain. This statement builds off of our previous statements and describes the actions planned for FY2024 and beyond.

INTRODUCTION

Orveon Global is committed to being responsible in its global business practices and takes steps with its product suppliers to ensure compliance with its standards of conduct as set forth in Orveon Global’s Supplier Code of Conduct and all applicable laws. Orveon Global has made and continues to make the following efforts to ensure compliance by its product suppliers:

OUR SUPPORT OF HUMAN RIGHTS

Orveon Global supports human rights across our global operations and value chain.

The UN Guiding Principles on Business and Human Rights provide a framework to help us identify and prioritise our human rights risks and impacts. Proactive human rights due diligence is an ongoing process, and we have policies, processes, training, and systems in place to identify, assess, monitor, and mitigate or eliminate actual or potential human rights impacts.

Orveon Global is required by the UK Modern Slavery Act 2015 to disclose publicly the steps the company is taking to identify and eradicate forced labour and human trafficking from our supply chains. The following describes Orveon Global’s relevant global commitments and initiatives.

ORGANISATIONAL STRUCTURE AND SUPPLY CHAINS

Orveon Global sources ingredients and materials from around the world to manufacture our beauty products. Our teams work diligently to source ingredients responsibly and with attention to potential impacts on people and environment. We aim to continuously strengthen our sourcing practices while remaining sensitive to the local communities in which we operate.

Orveon Global requires all product suppliers to confirm in writing that they understand and will adhere to the Orveon Global’s Supplier Code of Conduct. The Orveon Global Supplier Code of Conduct specifically requires product suppliers to certify that all goods are manufactured in compliance with the wage and hour, slavery and human trafficking laws of the country of manufacture and without the use of children or prison, indentured, exploited, bonded, forced, or slave labor.

The Code also specifies that Orveon Global Suppliers must not use or benefit from any form of human trafficking or forced or compulsory labour of any kind. Furthermore, workers must be allowed to leave their employment after giving reasonable notice. Imposing monetary fines, withholding identity papers (such as passports), work permits, remuneration or requiring recruitment deposits or other constraints as a condition of employment, is not allowed.

INTERNAL TRAINING

We promote a culture of ethics and integrity with standards to help us uphold the principles and ideals that make us a trusted global leader in beauty. We expect our employees and business partners to conduct business in compliance with applicable laws and regulations and with the high ethical standards and policies set forth in our Supplier Code of Conduct.

The Orveon Global’s global procurement and supply chain management teams are regularly trained on the requirements of the Orveon Global Supplier Code of Conduct and how to identify possible indicators of human trafficking and slavery in the supply chain to ensure that no risk factors are present.

SUPPLIER EVALUATION AND MONITORING

Orveon Global’s global procurement and supply chain management teams have the ability to audit product suppliers either itself or conduct an independent third-party assessment, including conducting on-site inspections to assess factory conditions and ensure that management is not in violation of slavery and human-trafficking laws. We monitor our suppliers to ensure adherence to the Code and pay careful attention to potential risks. We also monitor supplier performance and implement corrective action plans as needed.

ACCOUNTABILITY

Orveon Global will not do business with any supplier who will not agree to comply with the Orveon Global’s Supplier Code of Conduct or its other accountability standards. Orveon Global will issue a warning to any supplier, employee, or contractor who willfully or knowingly fails to comply with these standards and, if the supplier, employee, or contractor fails to take prompt corrective action, Orveon Global will enforce disciplinary action including termination of the business relationship.

Orveon Global is dedicated to conducting its business with integrity and the highest standard of ethics and seeks the same level of integrity and ethical standards with its vendor and supplier partners. Orveon Global will continue to assess all risks and opportunities to ensure that its approach will prevent any injustice or violation of human rights within its supply chain.

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Neela Montgomery

Chief Executive Officer

Orveon Global

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