GLINT
MarketplaceAuctions

MODERN SLAVERY STATEMENT

Our unwavering commitment to ethical business practices, human rights protection, and supply chain transparency in the luxury marketplace

EXECUTIVE SUMMARY

GLINT's 2025 Modern Slavery Statement

This statement is made pursuant to the Modern Slavery Act 2015 and sets out the steps that GLINT has taken and continues to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chains.

Statement Period: January 1, 2025 - December 31, 2025
Last Updated: July 19, 2025
Next Review: January 2026

Our Commitment

GLINT is committed to ensuring that there is no modern slavery or human trafficking in our business operations or supply chains. We have zero tolerance for any form of modern slavery and are committed to acting ethically and with integrity.

Our Responsibility

As a luxury marketplace platform, we recognize our responsibility to take a robust approach to slavery and human trafficking. We are committed to being transparent about our approach to tackling modern slavery.

OUR CORE COMMITMENTS

Four pillars of our modern slavery prevention framework

Zero Tolerance Policy

Absolute commitment to preventing modern slavery in all forms across our operations and supply chain

Key Measures:

  • Strict vetting procedures
  • Regular compliance audits
  • Immediate action protocols
  • Anonymous reporting systems

Supply Chain Transparency

Rigorous due diligence and monitoring of all partners, suppliers, and service providers

Key Measures:

  • Third-party verification
  • Regular assessments
  • Risk mapping
  • Continuous monitoring

Employee Protection

Comprehensive policies ensuring fair treatment, safe working conditions, and workers' rights

Key Measures:

  • Fair wages
  • Safe working environment
  • Freedom of association
  • Regular training programs

Legal Compliance

Full adherence to Modern Slavery Act 2015 and international human rights legislation

Key Measures:

  • Annual reporting
  • Legal framework compliance
  • International standards
  • Regular updates

RISK ASSESSMENT & MITIGATION

Comprehensive evaluation of potential risks and our mitigation strategies

Luxury Goods Sourcing

Medium Risk

Raw materials and manufacturing processes in luxury goods production

Mitigation Strategies:

Supplier certification
Regular audits
Traceability systems
Ethical sourcing requirements

Third-Party Services

Low Risk

Technology, logistics, and professional service providers

Mitigation Strategies:

Due diligence processes
Contractual obligations
Performance monitoring
Regular reviews

International Operations

Medium Risk

Cross-border transactions and international partnerships

Mitigation Strategies:

Country risk assessments
Local compliance
Cultural training
Partner verification

Authentication Services

Low Risk

Expert authentication and verification processes

Mitigation Strategies:

Certified experts
Transparent processes
Quality assurance
Ethical standards

ACTIONS TAKEN

Concrete steps we've implemented to prevent modern slavery

2025

Key Initiatives

Implemented enhanced supplier verification system
Conducted comprehensive risk assessment across all operations
Established dedicated ethics hotline for reporting concerns
Completed modern slavery awareness training for all staff
2024

Key Initiatives

Developed comprehensive supplier code of conduct
Integrated human rights clauses into all vendor contracts
Established partnership with ethical certification bodies
Implemented regular supply chain auditing program
2023

Key Initiatives

Created internal modern slavery prevention policies
Established cross-functional ethics committee
Began systematic review of all business relationships
Initiated staff training on human rights awareness

GOVERNANCE STRUCTURE

Multi-level oversight ensuring accountability at every organizational tier

Board Level

Strategic oversight and policy approval

Review: Quarterly reviews

Owner: CEO and Board of Directors

Executive Level

Implementation and operational oversight

Review: Monthly monitoring

Owner: Chief Compliance Officer

Operational Level

Day-to-day compliance and reporting

Review: Continuous monitoring

Owner: Department Heads

External Level

Independent auditing and verification

Review: Annual assessments

Owner: Third-party auditors

TRAINING & AWARENESS

Comprehensive education programs for all stakeholders

Executive Leadership

Annual
Participants:Senior Management
Content:

Strategic oversight, legal obligations, and governance responsibilities

Operations Staff

Bi-annual
Participants:All Employees
Content:

Recognition, reporting procedures, and prevention measures

Supplier Partners

Annual
Participants:Key Vendors
Content:

Compliance requirements, standards, and best practices

Specialized Training

Quarterly
Participants:Risk Teams
Content:

Advanced risk assessment, investigation, and remediation

PERFORMANCE METRICS

Measurable outcomes demonstrating our commitment effectiveness

100%

Supplier Compliance Rate

Target: 100%

Maintained
156

Risk Assessments Completed

Target: 150+

Exceeded
98%

Training Completion Rate

Target: 95%

Exceeded
0

Reported Incidents

Target: 0

Target Met

REPORTING MECHANISMS

Multiple secure channels for reporting concerns and violations

Anonymous Reporting

Secure, confidential channels for reporting concerns

ethics@glint.club

24/7 Available

Ethics Hotline

Dedicated phone line for immediate assistance

+1 (555) ETHICS-1

24/7 Support

Whistleblower Protection

Comprehensive protection for those reporting violations

Legal Protection

Full Confidentiality

Emergency Reporting

If you suspect immediate danger or urgent modern slavery concerns, contact emergency services immediately.

UK: Call 999 or Modern Slavery Helpline: 08000 121 700

US: Call 911 or National Human Trafficking Hotline: 1-888-373-7888

International: Contact local emergency services

FUTURE COMMITMENTS

Our ongoing dedication to strengthening anti-slavery measures

2025-2026 Priorities

  • Enhanced AI-powered supply chain monitoring
  • Expanded third-party certification requirements
  • Advanced training program development
  • Strengthened international partnerships

Continuous Improvement

  • Regular policy updates and reviews
  • Technology-enhanced due diligence
  • Industry collaboration and best practice sharing
  • Stakeholder engagement programs

TOGETHER AGAINST MODERN SLAVERY

Join us in our commitment to ethical business practices and human rights protection

This statement is approved by the GLINT Board of Directors and will be reviewed annually.

Last updated: July 19, 2025 | Next review: January 2026