Anti-Slavery & Human Trafficking Policy

Scope
This policy applies to all individuals working for the Company or on the Company’s behalf in any capacity, including employees at all levels, directors, officers, agency workers, external and internal consultants, interns, contractors, suppliers, volunteers, vendors, third party representatives and other business partners.

Policy Statement
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of an individual’s liberty by another in order to exploit them for personal or commercial gain. Langan has a zero-tolerance approach to modern slavery and human trafficking and is committed to acting ethically, with integrity and to providing transparency in its business dealings and relationships. To this end, the Company has implemented systems and controls to prevent modern slavery and human trafficking from taking place anywhere within either its own business or in any of its supply chains, consistent with its obligations under the UK Modern Slavery Act 2015.

Langan also expects the same high standards from all of its consultants, contractors, suppliers, volunteers, vendors, third party representatives and other business partners (collectively “Business Partners”). As part of its contracting processes, Langan includes specific prohibitions against the use of modern slavery and human trafficking, and expects its Business Partners to meet these same standards.

Reporting & Compliance
The prevention, detection and reporting of modern slavery and human trafficking, whether in the UK or abroad, is the responsibility of all those working for the Company or under the Company’s control. Individuals are required to avoid any activity that might lead to a violation of this policy. If you believe or suspect a violation of this policy has occurred or may occur, you must notify your immediate supervisor or any member of management, including a Company Stockholder, Human Resources, Langan’s General Counsel and/or the President/CEO. There may be times, however, when you may not want to report or discuss a concern with a member of the Company. In this case, you are encouraged to report the concern to the Langan Ethics Hotline, which is operated by a third party vendor named “Lighthouse.” The Hotline can be reached at: www.lighthouse-services.com/langan or by calling: 844-588-0002 for USA & Canada (English) and 800-603-2869 for all other countries (all other languages).

The Company prohibits detrimental treatment against anyone who in good faith provides information about a suspected violation of this policy. If you believe you have suffered any such treatment, you should inform Human Resources or Langan’s General Counsel immediately.

Communication & Awareness
The Company will communicate this policy to staff and all new hires. Training on this policy and its associated risks will be provided to employees as necessary. Langan’s zero-tolerance approach to modern slavery must be communicated to all Business Partners when entering into new or renewed contracts with them.

Violation of the Policy
Any employee who violates this policy will face disciplinary action, up to an including termination of employment. The Company may terminate its business relationships with Business Partners if they violate this policy and/or are found to have been involved in modern slavery and human trafficking.