LEGAL

INTRODUCTION

THIS MODERN SLAVERY STATEMENT IS MADE PURSUANT TO THE UK MODERN SLAVERY ACT 2015, THE AUSTRALIA MODERN SLAVERY ACT 2018 (NO. 153), AND THE CANADA FIGHTING AGAINST FORCED LABOUR AND CHILD LABOUR IN SUPPLY CHAINS ACT 2023. IT OUTLINES THE ACTIONS TAKEN BY ALASKA ETHEREAL DURING THE FINANCIAL YEAR ENDING 2025 TO ADDRESS THE RISKS OF MODERN SLAVERY, FORCED LABOUR, AND CHILD LABOUR WITHIN OUR OPERATIONS AND SUPPLY CHAIN. WE ARE COMMITTED TO ETHICAL BUSINESS PRACTICES AND ENSURING THAT HUMAN RIGHTS ARE RESPECTED ACROSS OUR ORGANIZATION AND THE ENTITIES WE ENGAGE WITH.

OUR STRUCTURE, OPERATIONS, AND SUPPLY CHAINS

ALASKA ETHEREAL IS A GLOBAL AMAZON WHOLESALE AND DISTRIBUTION COMPANY OPERATING IN NORTH AMERICA AND SELECT INTERNATIONAL MARKETS. WE ARE DEDICATED TO PRODUCING STRATEGIC GROWTH FOR CONSUMER BRANDS BY RESELLING THEIR PRODUCTS ON MAJOR ONLINE MARKETPLACES AND OFFERING VALUE-ADD SERVICES LIKE MARKETPLACE OPTIMIZATION, LOGISTICS COORDINATION, AND BRAND PROTECTION. WE WORK WITH A DIVERSE NETWORK OF SUPPLIERS GLOBALLY. OUR SUPPLY CHAIN INCLUDES SOURCING OF FINISHED GOODS, COORDINATION WITH BRAND-AUTHORIZED DISTRIBUTORS, AND PARTNERSHIPS WITH WAREHOUSING AND FULFILLMENT CENTERS TO ENSURE SEAMLESS DELIVERY ACROSS REGIONS.

WE RECOGNIZE THE RESPONSIBILITY WE HOLD TO ENSURE THAT OUR OPERATIONS AND SUPPLY CHAIN ARE FREE FROM MODERN SLAVERY, FORCED LABOUR, AND CHILD LABOUR, AND WE ARE COMMITTED TO IMPROVING TRANSPARENCY AND ADDRESSING RISKS PROACTIVELY.

POLICIES AND GOVERNANCE

WE HAVE IMPLEMENTED THE FOLLOWING POLICIES TO MITIGATE RISKS OF MODERN SLAVERY IN OUR OPERATIONS AND SUPPLY CHAIN:

  1. CODE OF CONDUCT: ESTABLISHING CLEAR EXPECTATIONS FOR ETHICAL PRACTICES, INCLUDING PROHIBITING FORCED LABOUR, CHILD LABOUR, AND HUMAN TRAFFICKING.
  2. SUPPLIER CODE OF ETHICS: REQUIRING SUPPLIERS TO COMPLY WITH INTERNATIONAL LABOUR STANDARDS AND APPLICABLE LAWS.
  3. WHISTLEBLOWING POLICY: PROVIDING A SAFE AND CONFIDENTIAL PLATFORM FOR REPORTING ANY VIOLATIONS OR UNETHICAL PRACTICES.
  4. HUMAN RIGHTS POLICY: ALIGNING WITH THE PRINCIPLES OF THE UN GUIDING PRINCIPLES ON BUSINESS AND HUMAN RIGHTS.

THESE POLICIES ARE REGULARLY REVIEWED AND COMMUNICATED TO EMPLOYEES, CONTRACTORS, AND SUPPLIERS.

RISK ASSESSMENT AND DUE DILIGENCE

WE HAVE ESTABLISHED A SYSTEMATIC APPROACH TO IDENTIFYING AND ADDRESSING RISKS OF MODERN SLAVERY IN OUR OPERATIONS AND SUPPLY CHAINS. THIS INCLUDES:

  1. RISK MAPPING: IDENTIFYING HIGH-RISK REGIONS, INDUSTRIES, AND SUPPLIERS.
  2. SUPPLIER ASSESSMENTS: CONDUCTING AUDITS AND DUE DILIGENCE PROCESSES TO ENSURE COMPLIANCE WITH OUR ETHICAL STANDARDS.
  3. CONTRACTUAL OBLIGATIONS: INCLUDING CLAUSES IN SUPPLIER CONTRACTS THAT PROHIBIT MODERN SLAVERY AND REQUIRE ADHERENCE TO OUR CODE OF CONDUCT.

REMEDIATION PROCESSES: COLLABORATING WITH STAKEHOLDERS TO ADDRESS IDENTIFIED ISSUES PROMPTLY.

TRAINING AND AWARENESS

WE PROVIDE TRAINING TO EMPLOYEES, SUPPLIERS, AND CONTRACTORS TO RAISE AWARENESS OF MODERN SLAVERY AND ITS RISKS. THIS INCLUDES:

  1. EDUCATING STAFF ON IDENTIFYING SIGNS OF FORCED LABOUR AND CHILD EXPLOITATION.
  2. PROVIDING GUIDANCE TO SUPPLIERS ON IMPLEMENTING ETHICAL PRACTICES.
  3. REGULAR UPDATES ON LEGAL REQUIREMENTS UNDER RELEVANT MODERN SLAVERY LEGISLATION.

MONITORING AND CONTINUOUS IMPROVEMENT

WE ARE COMMITTED TO CONTINUOUS IMPROVEMENT AND HAVE ESTABLISHED MONITORING MECHANISMS TO TRACK THE EFFECTIVENESS OF OUR EFFORTS. THESE INCLUDE:

  1. ANNUAL REVIEWS: ASSESSING PROGRESS IN MITIGATING MODERN SLAVERY RISKS.
  2. STAKEHOLDER ENGAGEMENT: COLLABORATING WITH INDUSTRY GROUPS, NGOS, AND GOVERNMENTS TO STRENGTHEN OUR APPROACH.

PUBLIC REPORTING: PUBLISHING AN ANNUAL STATEMENT TO ENSURE TRANSPARENCY AND ACCOUNTABILITY.

COMMITMENT TO TRANSPARENCY

ALASKA ETHEREAL UNDERSTANDS THE IMPORTANCE OF TRANSPARENCY IN COMBATING MODERN SLAVERY. THIS STATEMENT HAS BEEN APPROVED BY THE BOARD OF DIRECTORS AND REFLECTS OUR ONGOING COMMITMENT TO ETHICAL BUSINESS PRACTICES. WE WILL CONTINUE TO REVIEW AND ENHANCE OUR POLICIES AND PRACTICES TO ENSURE COMPLIANCE WITH MODERN SLAVERY LEGISLATION AND UPHOLD HUMAN RIGHTS ACROSS ALL ASPECTS OF OUR OPERATIONS. WE EXPECT THE SAME HIGH STANDARDS FROM OUR SUPPLIERS, PARTNERS, AND SERVICE PROVIDERS, AND ACTIVELY MONITOR OUR SUPPLY CHAIN TO IDENTIFY AND ADDRESS POTENTIAL RISKS. THROUGH COLLABORATION, ACCOUNTABILITY, AND CONTINUAL IMPROVEMENT, WE STRIVE TO BUILD A RESPONSIBLE AND RESILIENT BUSINESS THAT PROTECTS THE DIGNITY AND RIGHTS OF ALL INDIVIDUALS INVOLVED.

APPROVAL AND SIGN-OFF

THIS STATEMENT HAS BEEN APPROVED BY GREGORY FLAMMA, FOUNDER AND MANAGING DIRECTOR, ON BEHALF OF THE BOARD OF DIRECTORS OF ALASKA ETHEREAL. IT WILL BE REVIEWED AND UPDATED ANNUALLY.

SIGNED:
GREGORY FLAMMA
FOUNDER AND MANAGING DIRECTOR
MAY 3, 2025