Modern Slavery Statement

Wyvern Freight is a transport and logistics business based in Zimbabwe, with a registered branch in South Africa, supporting freight movements and related logistics activities across Southern Africa.

Our operations may involve employees, drivers, transport subcontractors, owner-drivers, customs and clearing agents, warehousing providers, labour providers, security providers, equipment suppliers and other vendors and service partners.

Because logistics relies on extensive networks of people and third parties, we recognise that responsible labour practices must extend beyond our directly employed workforce.

Wyvern Freight is committed to ensuring that work performed for or on behalf of our business is freely chosen and carried out under lawful and fair conditions.

We will not knowingly use or support any form of:

• slavery or servitude
• forced or compulsory labour
• human trafficking
• debt bondage
• unlawful child labour
• coercive or deceptive recruitment
• retention of workers' identity or travel documents as a means of control
• threats, intimidation or violence used to compel a person to work
• recruitment practices that place workers in exploitative debt
• restriction of a worker's freedom of movement for the purpose of exploitation

Employment with Wyvern Freight should be entered into voluntarily.

Employees should receive clear information about the terms and conditions of their employment, including their role, remuneration and applicable working conditions.

We expect employment practices to comply with applicable labour laws and regulations in the countries in which we operate.

Employees must be free to leave employment in accordance with applicable law and the terms of their employment arrangements.

Wyvern Freight does not permit managers, recruiters or other representatives to use threats, coercion, unlawful financial pressure or retention of identity documents to compel an individual to remain in employment.

Recruitment is an important area of modern-slavery prevention.

Where Wyvern Freight uses recruitment agencies, labour brokers or other employment intermediaries, we expect them to recruit workers lawfully and ethically.

Workers should not be charged improper recruitment fees as a condition of obtaining work with Wyvern Freight.

Recruiters must not misrepresent the nature of employment, wages, working conditions, location of work or other material terms.

Passports, national identity documents, work permits and other personal documents must not be confiscated or retained for the purpose of restricting a worker's freedom of movement.

Where documentation must temporarily be handled for legitimate administrative purposes, it should be returned promptly to the individual concerned.

No child may be employed or engaged in circumstances prohibited by applicable law.

Young workers who may lawfully work must not be assigned tasks that are dangerous, exploitative or inappropriate for their age.

We expect vendors and contractors working with Wyvern Freight to maintain equivalent standards.

Our responsibility extends into the supply chain.

Wyvern Freight expects carriers, transport subcontractors, labour providers, customs agents, warehouse operators, security providers and other vendors working for or on behalf of our business to respect fundamental human rights and prohibit modern slavery within their own operations.

Our expectations include:

• employment must be freely chosen
• forced and bonded labour are prohibited
• human trafficking is prohibited
• unlawful child labour is prohibited
• workers must be treated with dignity
• workers must not be subjected to threats, violence or coercion
• personal identification documents must not be withheld as a means of control
• wages and working arrangements must comply with applicable law
• recruitment must be conducted lawfully
• vendors should communicate equivalent expectations to relevant subcontractors

These principles should form part of Wyvern's vendor onboarding and ongoing supplier-management processes.

We recognise that some parts of the logistics industry can present a greater risk of labour exploitation than others.

Potential areas of increased risk can include:

• subcontracted road transport
• temporary and migrant labour
• labour supplied through third parties
• driver recruitment
• warehousing and cargo handling
• security and cleaning services
• cross-border operations
• outsourced or lower-tier subcontracting
• recruitment involving relocation or immigration arrangements

We aim to apply greater scrutiny where the nature of the service, geography, recruitment model or workforce characteristics indicate a higher potential risk.

Wyvern Freight seeks to assess relevant vendors and business partners before and during a commercial relationship.

Depending on the nature and level of risk, due diligence may include:

• confirming the identity and ownership of the business
• reviewing licences, registrations and operating credentials
• assessing labour and recruitment practices
• reviewing compliance with the Vendor Code of Conduct
• considering country, industry and service-specific risks
• requesting supporting policies or information
• following up on material concerns or adverse findings
• requiring corrective action where appropriate

Higher-risk relationships may require additional review.

Wyvern Freight reserves the right to decline, suspend or terminate a relationship where serious concerns cannot be appropriately resolved.

Modern-slavery and human-rights considerations should form part of our vendor onboarding process.

Vendors may be required to confirm that they:

• prohibit forced labour and human trafficking
• comply with applicable labour laws
• do not knowingly employ workers unlawfully
• maintain appropriate health and safety standards
• prohibit unlawful child labour
• provide truthful information during onboarding
• cooperate with reasonable compliance reviews
• report material breaches or concerns affecting Wyvern Freight operations

Providing false or misleading compliance information may result in rejection or termination of the business relationship.

Vendor onboarding enquiries: vendors@wyvernfreight.com

Our approach to modern-slavery risk should continue after onboarding.

Where appropriate, Wyvern Freight may review supplier information, investigate concerns, request updated documentation or conduct further due diligence.

The level of monitoring may vary according to the size, nature and risk profile of the relationship.

We aim to focus resources on areas where the potential impact on workers is greatest.

Employees involved in procurement, vendor management, recruitment, operations and management should understand the indicators of forced labour and human trafficking relevant to their responsibilities.

Where appropriate, Wyvern Freight will strengthen awareness and training as its compliance programme develops.

Employees, vendors, customers, drivers, contractors and other stakeholders are encouraged to report suspected modern slavery, trafficking or labour exploitation connected with Wyvern Freight's operations or supply chain.

Concerns may be reported through Wyvern Freight's Integrity Line or ethics reporting channels.

Report a concern

compliance@wyvernfreight.com

Reports should be treated seriously and as confidentially as reasonably possible.

A person who raises a genuine concern in good faith should not be subjected to retaliation for doing so.

Where Wyvern Freight becomes aware of a credible concern, we will seek to assess the circumstances and determine an appropriate response.

Depending on the circumstances, this may include:

• requesting further information
• conducting an internal review
• engaging with the relevant vendor
• requiring corrective action
• increasing monitoring
• suspending new work
• terminating the relationship
• referring the matter to an appropriate authority

The priority should be to prevent further harm and, where appropriate and possible, support access to remedy for affected individuals.

Termination should not automatically be treated as the only response where it could increase harm to affected workers. Appropriate corrective action should take account of the circumstances and the interests of potential victims.

Wyvern Freight intends to strengthen its ability to monitor the effectiveness of its modern-slavery controls as its compliance programme develops.

Measures may include:

• vendors screened during onboarding
• higher-risk vendors subject to additional review
• employees receiving relevant training
• modern-slavery or human-rights concerns reported
• investigations completed
• corrective actions agreed and closed
• vendor relationships suspended or terminated for serious non-compliance
• periodic review of policies and supplier standards

We will avoid publishing performance claims that cannot be supported by reliable records.

Responsibility for preventing modern slavery is shared across Wyvern Freight.

Management is responsible for setting expectations and supporting effective controls.

Employees involved in recruitment, procurement, vendor onboarding and operations are responsible for applying relevant requirements within their work.

Vendors and business partners are expected to cooperate with reasonable due-diligence and remediation requirements.

This statement should be reviewed periodically and updated where there are material changes to our operations, supply chain, legal requirements or identified risks.

Wyvern Freight respects the laws relating to forced labour, trafficking and worker protection applicable to its operations.

In Zimbabwe, the Constitution protects freedom from slavery, servitude and forced or compulsory labour; the Labour Act prohibits forced labour; and the Trafficking in Persons Act addresses trafficking, including exploitation through forced labour and debt bondage.

In South Africa, the Constitution provides that no person may be subjected to slavery, servitude or forced labour. The Basic Conditions of Employment Act also prohibits forced labour, while the Prevention and Combating of Trafficking in Persons Act establishes offences and measures directed at trafficking in persons.

Our standards are also informed by internationally recognised principles concerning human rights, labour rights and responsible business conduct.

• Code of Ethics
• Integrity Line
• Privacy & Data Protection

Statement owner

Wyvern Freight

Applicable operations

Zimbabwe and South Africa

Reporting period

[Year]

Approved by

[Director / Board / Managing Director]

Approval date

[Date]