Anti-Slavery & Anti-Trafficking Policy

1. Purpose

Tilli is committed to maintaining the highest ethical standards in all our business dealings. This policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains or in any part of our business.

2. Scope

This policy applies to all persons working for Tilli or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

This policy applies to all our activities and operations globally, including but not limited to our offices in McLean, Virginia, and all international operations.

3. Our Commitment

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We implement due diligence procedures for our supply chains and contractors to ensure compliance with this policy.

• We conduct regular risk assessments to identify and address potential slavery and trafficking risks
• We maintain transparent supplier relationships and expect the same high standards from our contractors and suppliers
• We provide training to relevant employees to ensure understanding of modern slavery risks
• We maintain a zero-tolerance approach to modern slavery and human trafficking

4. Procedures

To ensure compliance with this policy, we have implemented the following procedures:

4.1 Due Diligence

• Supplier audits and assessments
• Contractual obligations requiring compliance with anti-slavery laws
• Regular monitoring and review of supply chain practices

4.2 Reporting

• Clear reporting channels for concerns about modern slavery
• Protection for whistleblowers
• Investigation procedures for reported concerns

4.3 Training

• Regular training for procurement and HR staff
• Awareness programs for all employees
• Specific training for high-risk roles

5. Disciplinary Actions

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy.

6. U.S. Government Policy

In accordance with U.S. Government policy, Tilli strictly prohibits:

• Trafficking in persons during the period of performance of any contract
• Procurement of commercial sex acts during the period of performance of any contract
• Use of forced labor in the performance of any contract
• Destruction, concealment, or confiscation of identity or immigration documents
• Use of misleading or fraudulent recruitment practices
• Charging employees recruitment fees

7. Reporting Concerns

If you have any concerns about modern slavery or human trafficking in relation to Tilli's operations or supply chains, please report them immediately to:

8. Review and Updates

This policy will be reviewed annually and updated as necessary to ensure it remains current and effective. The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations.