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Modern Slavery Statement

Improbable Group: Modern Slavery Statement (from 1 January 2023 to 31 December 2023)

OUR BUSINESS
  1. This statement has been prepared for Improbable Worlds Limited and its subsidiaries (the 'Improbable Group', 'Improbable', 'we', 'us', 'our') in respect of our financial year 1 January 2023 to 31 December 2023. Improbable Worlds Limited is a private limited company incorporated and registered in England and Wales. Improbable has several wholly-owned subsidiaries including: The Multiplayer Group Limited, Improbable MV Limited, Improbable Inc, Improbable SG PTE Ltd, Improbable Canada Limited, Improbable Worlds Nominees Limited, and Improbable Seattle Inc.
  2. We're Improbable, we deliver technology, expertise, creativity and services to help customers unleash the full potential of virtual worlds and the metaverse. More than 800 people work for Improbable, across the United Kingdom and internationally. Even though we don't operate in sectors and regions that have a high risk of modern slavery, we're committed to taking appropriate steps to make sure there's no modern slavery or human trafficking in any part of our business or supply chain. This is the first Modern Slavery Statement for the Improbable Group.
  3. 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 a person's liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
  4. We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our employees (including any contract employees and secondees), consultants to and representatives of Improbable, and its subcontractors and suppliers.
  5. This statement applies to all persons working for Improbable or on our behalf in any capacity, including all Improbable employees, and any representatives of Improbable, including subcontractors and suppliers.
  6. This policy does not form part of any employee's contract of employment, and we may amend it at any time.
RESPONSIBILITY
  1. Improbable as a company has a responsibility for ensuring this statement complies with our legal and ethical obligations and that all those under our control comply with it.
  2. Our senior management team has primary and day-to-day responsibility for implementing this statement, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
  3. Management at all levels are responsible for ensuring those reporting to them understand and comply with this statement and are given adequate and regular training on it and the issue of modern slavery in supply chains.
  4. Employees are invited to comment on this statement and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the VP People or Chief Legal Officer.
STATEMENT
  1. Improbable recruits and treats employees fairly. We recruit and select employees in a fair, lawful, and professional manner, both for internal and external candidates. We treat all employees fairly and consistently during their employment and have in place procedures to raise a grievance if an employee feels they have been treated unfairly. We also manage employee exits in the same spirit, in compliance with all local legal requirements.
  2. Improbable are committed to labour and workplace rights. We provide fair working conditions for all our employees including terms and conditions of employment, remuneration, working hours, health and safety, resting time, holiday entitlements and benefits in full compliance with statutory requirements. Improbable reserves the right to terminate a relationship with a supplier or third party as an ultimate sanction where the supplier fails to demonstrate compliance or progress towards the eradication of modern slavery within its own organisation and supply chain.
  3. Improbable's Code of Conduct defines the expectations we have to always do what's right, to conduct ourselves with integrity, and hold ourselves and others accountable to high standards of ethical conduct.
  4. Improbable's Whistleblowing Policy highlights how to report whistleblowing, how whistleblowers are protected, and how they are reported and protected. Improbable employees can speak to their line manager, people partner, any senior manager or director. We do our best to create an environment where people feel safe and empowered to raise concerns without any fear of reprisal.
  5. Improbable's Equal Opportunities & Discrimination Policy aims to show our commitment to promoting equal opportunities regardless of age, disability, gender, reassignment, marital or civil partnership, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation.
  6. Improbable's Anti-Harassment, Bullying & Misconduct Policy sets out our approach to tackling direct and indirect harassment, victimisation and discrimination. The policy aims to ensure if someone believes there has been inappropriate behaviour, performance or conduct on the part of Improbable, its management, employees, vendors, customers or any other persons or entities related to Improbable that they have access to a process where they feel heard and listened to.
  7. Improbable's Anti-Corruption and Bribery Policy sets out our approach to tackling bribery and corruption. Anyone found in violation of these rules will face serious disciplinary consequences, including where appropriate relevant legal sanctions.
  8. Improbable's Grievance Policy shows we are committed to fostering an environment where people feel they are able to raise any concern without hesitation. We believe the overarching Grievance guidance should focus on trust and transparency, ensuring that every conversation on this topic is handled with respect, as quickly as possible, and ensures a fair outcome.
COMPLIANCE
  1. The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. Employees are required to avoid any activity that might lead to, or suggest, a breach of this statement.
  2. Employees must notify their manager or the VP People or Chief Legal Officer as soon as possible if they believe or suspect that a conflict with this statement has occurred, or may occur in the future.
  3. If employees do not feel comfortable reporting their concerns or suspicions to the VP People or Chief Legal Officer, they may notify their concerns through the Whistleblowing Policy mentioned above (which provides a process for reporting concerns anonymously).
  4. If employees are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with the VP People or Chief Legal Officer.
  5. Improbable aims to encourage openness and will support anyone who raises genuine concerns in good faith under this statement, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in our supply chain.
THIRD PARTIES
  1. Consultants, representatives, subcontractors and suppliers may be retained to promote Improbable's business or otherwise assist Improbable in operating and carrying out its business and activities, including with regard to any necessary interaction with Government or Public Officials.
  2. Such third parties may only be engaged by the Improbable following completion of applicable internal company due diligence, contracting and approvals procedures and such parties are expected to comply with all applicable laws including in respect of modern slavery.
  3. In accordance with its obligations under the Modern Slavery Act 2015, Improbable will publish all necessary statements and requires all suppliers, contractors, representatives and consultants to inform Improbable if they become aware of any information which may indicate that modern slavery is occurring in their business or supply chain. They are also expected to inform Improbable of any positive changes they make to ensure there is no modern slavery in their business or supply chain.
BREACHES
  1. Any employee who breaches this statement or any of the obligations outlined in the UK Modern Slavery Act may face disciplinary action, which may result in dismissal.
  2. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this statement including contractors, suppliers, representatives and consultants.
TRAINING AND COMMUNICATION
  1. To make employees aware of the Modern Slavery Act and the drivers of modern slavery, as well as the possible indicators, this statement has been shared with all employees through our internal communication channels and there are training modules on Modern Slavery. It is also available on our website https://www.improbable.io. Any person with queries or concerns can enquire directly to legal@improbable.io.
BOARD APPROVAL
  1. This statement is made pursuant to section 54(1) of the Act, has been approved on June 28th, 2023 by the Board of Directors of Improbable, and will be updated annually in line with the Modern Slavery Act's reporting requirements. Approved by Herman Narula, Chief Executive Officer, June 28th, 2023