Modern Slavery Policy

The Clubhouse Modern Slavery Policy

Introduction

The Clubhouse is committed to conducting its business ethically and responsibly. We recognize the responsibility we share with our employees, suppliers, and partners to operate in a manner that respects human rights and is free from modern slavery and human trafficking. This Modern Slavery Policy outlines our stance against modern slavery and sets forth the measures we have implemented to ensure slavery and human trafficking are not taking place in our business operations or supply chains.

Scope

This policy applies to all individuals working at all levels of The Clubhouse, including senior managers, officers, directors, employees (whether permanent, fixed-term, or temporary), consultants, contractors, trainees, seconded staff, homeworkers, volunteers, interns, agents, or any other person associated with us, or any of our subsidiaries or their employees, no matter where they are located.

Definitions

For the purposes of this policy, the term "modern slavery" encompasses:

• Human trafficking
• Forced labor
• Debt bondage
• Child labor
• Forced marriage
• Commitment

The Clubhouse commits to:

Identifying Risks: Regularly review and assess the risks of modern slavery in our operations and supply chain.

Due Diligence: Conduct due diligence on suppliers, contractors, and partners to ensure they adhere to our ethical standards.

Awareness and Training: Provide training to employees and management on modern slavery and human trafficking, including how to identify and report potential violations.

Reporting and Whistleblowing: Encourage the reporting of concerns related to direct or indirect involvement in modern slavery, ensuring that the process for reporting is clear,

confidential, and can be done without fear of retaliation.

Continuous Improvement: Regularly update our policies and procedures to prevent slavery and human trafficking in our business operations and supply chain.

Supplier Code of Conduct

We expect our suppliers and contractors to comply with our values and ethical standards, including this Modern Slavery Policy. Any breach of human rights, including any form of modern slavery, within our supply chain, is unacceptable and will prompt an immediate review of our contractual relationship, potentially leading to termination.

Reporting Concerns

Employees and external stakeholders are encouraged to report any concerns or suspicions of modern slavery in any parts of our business or supply chains of any supplier tier to [insert reporting mechanism details].

Policy Review

This policy will be reviewed and updated regularly to reflect our ongoing commitment to ensuring that our operations and supply chains remain free from modern slavery and human trafficking.