Modern Slavery Statement

1. Organizational Structure & Supply Chains

Zentish Exim Pvt Ltd ("Company", "we", "us", "our") is a privately held chemical distribution and export company headquartered in India. We source, distribute, and export menthol crystals, essential oils, aroma chemicals, and related chemical products to customers in over 25 countries across North America, Europe, the Middle East, Asia-Pacific, and Africa.

Our supply chains encompass raw material procurement from primary producers (farmers, plantations, mines), chemical manufacturers, distillation units, packaging suppliers, logistics providers, and freight forwarders across India and internationally. Key raw materials include mentha oil (from Uttar Pradesh/Barabanki), peppermint, spearmint, eucalyptus, and various aroma chemicals.

2. Policies in Relation to Slavery and Human Trafficking

We are committed to ensuring that modern slavery and human trafficking have no place in our operations or supply chains. Our approach is governed by:

• Code of Conduct & Ethics:Explicitly prohibits forced labor, child labor, human trafficking, and modern slavery. Binding on all employees and contractors.
• Supplier Code of Conduct:Requires all suppliers to prohibit forced labor, child labor, human trafficking, and to respect freedom of association and collective bargaining.
• Whistleblower Channel:Anonymous reporting mechanism for modern slavery concerns with zero retaliation protection.
• Human Rights Commitment:Alignment with UN Guiding Principles on Business and Human Rights and ILO core conventions.

3. Due Diligence Processes

We undertake the following due diligence to identify and mitigate modern slavery risks:

• Supplier Onboarding:All new suppliers complete a self-assessment questionnaire covering modern slavery, labor practices, and human rights. High-risk suppliers undergo enhanced due diligence.
• Risk-Based Supplier Assessment:Suppliers are categorized by risk (geography, industry, workforce type). High-risk suppliers (e.g., agriculture, mining, labor-intensive manufacturing in high-risk jurisdictions) receive on-site audits.
• Supply Chain Mapping:We map key raw material supply chains to the farm/plantation/mine level where feasible to identify forced labor risks.
• Contractual Requirements:Purchase orders and supplier agreements include modern slavery compliance clauses with audit rights and termination for non-compliance.
• Third-Party Audits:High-risk suppliers subject to third-party social audits (SMETA/SEDEX or equivalent) every 24 months.

4. Risk Assessment & High-Risk Areas

We have identified the following areas as having elevated modern slavery risk in our sector and geography:

• Agricultural Raw Materials:Mentha/peppermint/spearmint cultivation in Uttar Pradesh/Barabanki — seasonal migrant labor, informal labor arrangements.
• Mining & Extractives:Raw material sourcing for certain aroma chemicals — artisanal mining, informal labor.
• Logistics & Warehousing:Contract labor in loading/unloading, packaging — potential for contractor exploitation.
• Sub-Contracted Manufacturing:Third-party distillation/processing units — subcontracted labor visibility.

We prioritize due diligence and monitoring resources on these high-risk categories.

5. Key Performance Indicators (KPIs)

We track the following metrics to measure effectiveness of our anti-slavery efforts:

• % of Tier 1 suppliers completing modern slavery self-assessment:Target 100%
• % of high-risk suppliers audited (SMETA/equivalent) within 24 months:Target 100%
• Number of modern slavery concerns reported via whistleblower channel:Target 0 (investigated promptly)
• % of supplier contracts with modern slavery clauses:Target 100%
• Employee training completion rate on modern slavery awareness:Target 100%

6. Training & Awareness

• Annual mandatory modern slavery awareness training for all procurement, supply chain, compliance, and senior management personnel.
• Supplier awareness webinars on modern slavery expectations and reporting mechanisms.
• Internal communications (posters, intranet, town halls) to raise employee awareness.

6. Remediation & Reporting

• Any identified modern slavery incident triggers immediate investigation per our incident response protocol.
• Victim-centered remediation: prioritize victim safety, coordinate with authorities/NGOs, provide access to remedy.
• Supplier non-compliance triggers corrective action plans with defined timelines; persistent non-compliance leads to contract termination.
• Annual board-level review of modern slavery risks, incidents, and mitigation effectiveness.

7. Continuous Improvement

We recognize that combating modern slavery requires ongoing vigilance. In the coming year, we commit to:

• Expanding supply chain mapping to Tier 2/Tier 3 for high-risk raw materials.
• Implementing a grievance mechanism accessible to workers in our extended supply chain.
• Participating in industry collaborations (e.g., Stronger Together, Sedex) to share best practices.
• Enhancing worker voice mechanisms in high-risk supplier facilities.

8. Approval & Sign-Off

This statement has been approved by the Board of Management of Zentish Exim Pvt Ltd pursuant to Section 54(1) of the Modern Slavery Act 2015.

Contact

Questions or concerns about this statement or to report a modern slavery concern:

• Email:compliances@zentish.com
• Whistleblower Form:Anonymous Web Form