Modern Slavery Policy

Statement of principle

GW LASER TECHNOLOGY S.R.L., hereinafter Uzinex, firmly and unequivocally declares that it holds a position of zero tolerance towards any form of modern slavery, human trafficking, forced labour, child labour, debt bondage or human exploitation, whether these practices occur within its own operations, among its direct employees, subsidiaries, suppliers, subcontractors or any third party with which Uzinex has business relationships. This policy reflects the fundamental values of the company: respect for human dignity, fairness, legality, transparency and social responsibility.

Legal framework and international standards

This policy is aligned with the following legal instruments and international standards: (1) ILO Convention No. 29 on forced labour (1930); (2) the 2014 Protocol to ILO Convention No. 29; (3) ILO Convention No. 105 on the abolition of forced labour (1957); (4) ILO Convention No. 138 on the minimum age (1973); (5) ILO Convention No. 182 on the worst forms of child labour (1999); (6) the UN Universal Declaration of Human Rights (1948); (7) the UN Guiding Principles on Business and Human Rights (UNGPs); (8) the UN Global Compact; (9) the UN Protocol to Prevent, Suppress and Punish Trafficking in Persons (the Palermo Protocol, 2000); (10) EU Directive 2011/36 on preventing and combating trafficking in human beings; (11) Law No. 678/2001 on preventing and combating trafficking in persons in Romania; (12) national labour legislation, including the Labour Code and Law 53/2003.

Essential definitions

• —Modern slavery — an umbrella term covering all forms of exploitation in which one person is controlled by another through coercion, violence, threat, abuse of power or a position of vulnerability, for the purpose of exploitation.
• —Human trafficking — the recruitment, transport, transfer, harbouring or receipt of persons through threat of force, use of force, coercion, abduction, fraud or deception, for the purpose of exploitation.
• —Forced labour — any work or service demanded of a person under the threat of any penalty and for which the person has not offered themselves voluntarily.
• —Debt bondage — when a person's labour is provided as security for a debt, and the value of the labour is not applied to the debt.
• —Child labour — any work that deprives children of their childhood, potential and dignity and that is harmful to their physical and mental development.
• —Exploitation — includes, but is not limited to: the exploitation of prostitution, other forms of sexual exploitation, forced labour, slavery, practices similar to slavery, servitude or the removal of organs.

Areas of application of the policy

This policy applies to all Uzinex operations, including: the activities carried out at the registered office and workplaces, relationships with direct employees and collaborators, the selection and management of equipment and component suppliers, contracts with subcontractors for installation, maintenance and service services, relationships with distributors and commercial partners, projects implemented at clients — including those in the private, public and defence sectors — and all the global supply chains that Uzinex uses.

Risk assessment

• —We assess the risks of modern slavery in the supply chain based on several factors: the country of origin of suppliers, the industrial sector, product complexity, the transparency of commercial relationships, the suppliers' track record on labour rights.
• —We pay special attention to regions with a known risk of forced labour or human trafficking, according to international reports such as the Global Slavery Index and the US State Department's Trafficking in Persons Report.
• —We monitor updates to the international sanctions lists targeting entities involved in modern slavery or human rights violations.
• —For medium- or high-risk suppliers, we request conformity declarations, due-diligence questionnaires and, where necessary, independent audits.

Supplier selection and monitoring

• —All Uzinex suppliers and partners must expressly accept the principles of this policy as an integral part of the contractual relationship.
• —We ask suppliers to confirm in writing that they comply with the applicable labour legislation, the international ILO standards and do not use forced labour, child labour or debt bondage.
• —For high-value contracts or strategic relationships, we carry out periodic checks through due diligence, audits and, where necessary, on-site visits.
• —We reserve the right to terminate immediately any contract if practices incompatible with this policy are discovered, without any obligation to compensate the supplier.
• —We prefer to work with suppliers certified to international standards such as SA8000, ISO 45001, BSCI, SEDEX SMETA.

Protection of Uzinex employees

Uzinex undertakes to offer all its employees: (1) legal, written employment contracts, compliant with the Romanian Labour Code and the applicable collective labour agreements; (2) decent wages, at a level at least equal to the nationally guaranteed minimum wage, paid on time and without delays; (3) compliance with legal working hours, with fair compensation for overtime; (4) safe and healthy working conditions, in accordance with occupational health and safety standards and specific legislation; (5) freedom of association and the right to collective bargaining; (6) the prohibition of discrimination on any criterion (race, sex, religion, origin, etc.); (7) the prohibition of forced labour, child labour and any form of exploitation; (8) clear procedures for reporting abuses, with whistleblower protection; (9) regular training on labour rights and recognizing the signs of exploitation.

Mechanism for reporting suspicions

Any person — Uzinex employee, supplier, commercial partner, client, community member — who observes or suspects practices that contravene this policy can confidentially report the situation to: a dedicated email info@uzinex.ro (with the subject [WHISTLEBLOWER]), phone (+40) 769 081 081, in writing at the company's office. All reports are: (1) received and evaluated seriously, regardless of the source; (2) investigated objectively and within a reasonable time; (3) treated confidentially, with complete protection of the reporter against any retaliation; (4) followed by concrete actions where the identified issues are confirmed; (5) documented in the internal compliance reports. Uzinex guarantees that no good-faith reporter will be sanctioned, penalized or discriminated against as a result of reporting.

Investigations and remediation

In the event that modern slavery practices are discovered within its own operations or in the supply chain, Uzinex takes the following measures: (1) an immediate internal investigation, led by a dedicated team; (2) cooperation with the competent authorities (the Romanian Police, DIICOT, the Labour Inspectorate, the General Directorate for Social Assistance); (3) measures to protect and assist victims (contact with specialized NGOs, counselling, rehabilitation); (4) disciplinary or contractual sanctions for the responsible persons and entities; (5) remediation of the conditions that allowed the abuse; (6) public communication, where appropriate, about the measures taken; (7) reporting to the relevant international authorities and partners, in accordance with legal obligations.

Training and awareness

Uzinex organizes periodic training sessions for employees, with a focus on: recognizing the signs of modern slavery and human trafficking, the procedures for reporting suspicions, the rights and obligations set out in the Labour Code, the impact of commercial decisions on the supply chain. For managers and staff responsible for procurement, the training includes advanced modules on due diligence, supplier audits and the assessment of geographic risks.

Transparency and reporting

Uzinex is committed to transparency regarding its efforts to combat modern slavery. Annually, we publish a compliance report that includes: the assessment of supply-chain risks, the measures taken for prevention, the results of the audits carried out, any incidents reported and how they were handled, and the improvement plans for the following year. The report is available on request at info@uzinex.ro and, for EU-funded projects, is integrated into the DNSH and social conformity documentation.