Modern Slavery and Human Trafficking Statement

TenTrinity (Guernsey) Ltd (the “Company”, “we”, “us”, or “our”) is committed to operating its business, and to working with its counterparties, in a manner that excludes modern slavery, human trafficking, forced labour, debt bondage, servitude, and the worst forms of child labour, whether in our own operations, in our supply chains, in the counterparty relationships we form, or in the carbon project portfolios with which we engage.

This statement sets out the steps that the Company has taken, and intends to take, to identify, assess, prevent, mitigate, and where appropriate remediate, the risk of modern slavery and human trafficking in connection with our business. It is published voluntarily and is intended to satisfy, on a substantive basis, the disclosure expectations applicable in each of the jurisdictions identified in clause 3, whether or not the Company is at the date of this statement subject to a binding statutory obligation in those jurisdictions.

This statement covers the financial year ended [•] and supersedes any prior statement. It will be reviewed and updated annually, or more frequently if a material change in the Company’s operations, counterparty relationships, or risk profile warrants earlier revision.

TenTrinity (Guernsey) Ltd is a private company incorporated in the Bailiwick of Guernsey with registered number CMP76555 and registered office at Suite G, St Peter Port House, Sausmarez Street, St Peter Port, Guernsey GY1 2PT, Channel Islands. The Company is headquartered, managed, and controlled in Guernsey. We do not maintain operating subsidiaries in other jurisdictions; where this statement refers to “our operations”, it refers to the activities of the Company itself.

The Company carries on a voluntary-carbon-markets business comprising the procurement, structuring, advisory, and administration activity described in the public materials available on the Company’s website. Our work brings us into commercial relationship with carbon-project developers, methodology bodies, registries, ratings agencies, validation and verification bodies, insurers, intermediaries, financial counterparties, and end purchasers of carbon credits, in multiple jurisdictions on five continents.

The Company is small in headcount and large in counterparty reach. That asymmetry is the central fact that shapes our modern slavery risk profile: the residual risk does not arise from direct employment or from the Company’s office operations in Guernsey; it arises from the upstream conduct of the carbon project counterparties whose credits the Company procures, advises on, or otherwise interacts with, and from the labour conditions prevailing in the regions in which those projects operate.

The Company has had regard, in the preparation of this statement, to the substantive disclosure and due-diligence expectations of the following regimes, whether or not legally binding on the Company at the present time:

• (a) the United Kingdom Modern Slavery Act 2015, in particular section 54;
• (b) the Australian Modern Slavery Act 2018 (Cth);
• (c) the California Transparency in Supply Chains Act of 2010;
• (d) the French Loi n° 2017-399 du 27 mars 2017 relative au devoir de vigilance;
• (e) the Norwegian Act relating to enterprises’ transparency and work on fundamental human rights and decent working conditions (Åpenhetsloven);
• (f) the German Lieferkettensorgfaltspflichtengesetz (LkSG);
• (g) the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act (S-211);
• (h) the European Union Corporate Sustainability Due Diligence Directive (Directive (EU) 2024/1760, CSDDD), as it comes into force and is transposed in the relevant member states;
• (i) Title 19 of the United States Code section 1307 (prohibition on importation of goods produced by forced or indentured labour);
• (j) the Uyghur Forced Labor Prevention Act of 2021 (UFLPA), in so far as goods or services originating from the Xinjiang Uyghur Autonomous Region may at any time enter our supply chain;
• (k) the prohibition under the Sanctions and Anti-Money Laundering Act 2018 and the Bailiwick of Guernsey’s Sanctions (Bailiwick of Guernsey) Law, 2018 on dealings with sanctioned persons, including those sanctioned for human-rights violations under Global Human Rights Sanctions regimes (the United Kingdom, the United States Office of Foreign Assets Control, the European Union, Canada, Australia, and the Bailiwick of Guernsey).

The Company adheres to, and applies, the following international frameworks:

• (a) the United Nations Guiding Principles on Business and Human Rights (2011);
• (b) the International Labour Organization Declaration on Fundamental Principles and Rights at Work, including ILO Conventions No. 29 (1930), No. 105 (1957), No. 138 (1973), and No. 182 (1999);
• (c) the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (2023);
• (d) the United Nations Global Compact, in particular Principles 1, 2, 4, and 5;
• (e) the International Finance Corporation Performance Standard 2 on Labour and Working Conditions, in respect of project-level expectations;
• (f) the Integrity Council for the Voluntary Carbon Market Core Carbon Principles, in particular the Sustainable Development Benefits and Safeguards principle, and the supporting Assessment Framework requirements relating to human rights, labour rights, and Free, Prior and Informed Consent;
• (g) the Voluntary Carbon Markets Integrity Initiative Claims Code of Practice, including its expectation that credits used for compliant claims meet credible threshold-quality standards including respect for human rights.

Where the Company’s carbon project counterparties are themselves subject to registry-level safeguards including the Verra VCS Programme’s environmental and social safeguards, the Gold Standard for the Global Goals’ Safeguarding Principles and Requirements, the ACR Standard, or Puro.earth’s General Rules, the Company expects, and verifies through diligence, that those safeguards are observed.

The Company has carried out, and maintains under continuous review, an internal risk assessment that identifies the categories of modern slavery and human trafficking risk most relevant to the Company’s business.

4.1 Operational risk (low)

The Company employs a small number of professionally qualified individuals in Guernsey, with directly contracted employment terms compliant with the Employment Protection (Guernsey) Law, 1998 and ancillary legislation, and at remuneration levels materially in excess of Guernsey’s statutory minimum. The Company does not engage agency labour, does not operate manufacturing or extractive activities, does not retain identity documents, does not impose recruitment fees, and does not engage in any practice that would constitute a modern slavery indicator under recognised typologies.

4.2 Professional services supply chain risk (low)

The Company procures a modest range of professional and corporate services from established providers in jurisdictions with mature labour protections. The Company assesses professional-services supply chain risk as low but not negligible, and applies the supplier engagement controls described in clause 6 to confirm that assessment on a continuing basis.

4.3 Counterparty risk (moderate)

The Company transacts with carbon credit purchasers, financial intermediaries, custodians, and registries, the majority of which are themselves subject to robust anti-money-laundering, sanctions, and reputational diligence. The Company nonetheless screens all counterparties for adverse media, sanctions exposure, regulatory enforcement, and litigation involving human-rights or labour-rights allegations, as part of its onboarding and continuing-relationship process. Counterparty risk is assessed as moderate by reference to the geographies in which some counterparties operate.

4.4 Carbon project portfolio risk (elevated and primary)

This is the principal area of modern slavery and human trafficking risk to which the Company is exposed. The carbon projects with which the Company engages are located in or source from jurisdictions including the Democratic Republic of the Congo, Brazil, the Republic of Gabon, Peru, Bolivia, and other countries with significant areas of tropical forest, mangrove, peatland, or grassland that are the subject of voluntary-carbon-market activity. In those geographies the following risk indicators are present in varying degrees:

• (a) Forest community labour conditions: smallholder reforestation, afforestation, improved forest management, or REDD+ projects engage local and indigenous community labour; wage payment irregularity, in-kind compensation, debt-financed inputs, and undocumented seasonal labour are recognised risks.
• (b) Indigenous and local community rights: failure of Free, Prior and Informed Consent, manipulation of benefit-sharing, or exclusion from carbon revenue flows is itself a human-rights concern and may co-occur with labour exploitation.
• (c) Migrant labour in plantation forestry: afforestation and reforestation projects relying on commercial plantation models have, in documented cases, engaged migrant labour in conditions ranging from substandard to coercive.
• (d) Adjacent extractive activity: forest carbon projects in landscapes that also host artisanal small-scale mining, illegal logging, or wildlife trafficking are at heightened risk of contamination by labour practices in those adjacent activities, including child labour and debt bondage.
• (e) Conflict and post-conflict settings: in jurisdictions including the eastern provinces of the Democratic Republic of the Congo, the prevailing security environment increases vulnerability to coerced and child labour and complicates direct verification.
• (f) Blue carbon and coastal community projects: mangrove restoration, seagrass conservation, and coastal wetland carbon projects rely on coastal-community labour and on fisheries-adjacent labour markets, the latter of which has well-documented modern slavery exposure in several Indian Ocean and Pacific Ocean jurisdictions.
• (g) Methodology-specific risks: methodologies that quantify benefits to communities or that rely on community implementation create points at which payments, records, and labour can be misreported.

The Company’s project-level diligence (clause 7) is the primary control by which the elevated carbon-project-portfolio risk is managed.

The board of directors holds ultimate responsibility for the matters covered by this statement. The board reviews modern slavery and human-rights risk no less than annually, and on the occasion of any material change in the Company’s operations, counterparty relationships, or portfolio.

Day-to-day responsibility for the operation of the policies, processes, and controls described in this statement rests with [•], whose role includes maintaining counterparty and project diligence, maintaining the supplier engagement framework, escalating to the board any finding, allegation, or concern relating to modern slavery or human trafficking in any aspect of the Company’s business, and coordinating any remedial response described in clause 9.

No member of the board, no officer, and no employee of the Company is permitted to overrule a diligence outcome that has identified a credible modern slavery or human-trafficking concern. Where such a concern is identified, the matter is escalated for board-level decision and, in appropriate cases, for notification to relevant authorities.

The Company maintains the following policies, each of which addresses, directly or indirectly, modern slavery and human-trafficking risk:

• (a) an Anti-Money-Laundering, Counter-Terrorist-Financing, and Sanctions Policy, including a Human-Rights Sanctions screening procedure;
• (b) a Counterparty Onboarding and Continuing Diligence Policy, including reputational, regulatory, and adverse-media screening;
• (c) a Supplier Code of Conduct, which sets out the Company’s expectations of suppliers in respect of labour rights, forced labour, child labour, freedom of association, and grievance mechanisms;
• (d) a Whistleblowing and Speaking-Up Policy, providing a confidential channel for the reporting of concerns, including modern slavery concerns, with anti-retaliation protection;
• (e) a Carbon Integrity and Project Diligence Policy;
• (f) a Travel and Field-Visit Protocol, governing the conduct of staff and engaged consultants when visiting project sites in higher-risk jurisdictions.

Counterparties and suppliers are screened, at onboarding and at scheduled re-review, against all relevant sanctions lists; commercial adverse-media databases for human-rights, labour-rights, environmental, and integrity-related findings; regulatory enforcement databases in their primary jurisdiction of operation; the politically-exposed-persons and beneficial-ownership databases relevant to financial-crime risk; and, where the counterparty operates in a higher-risk geography or sector, additional country- and sector-specific human-rights resources, including the US Department of State Trafficking in Persons Report, the US Department of Labor List of Goods Produced by Child Labor or Forced Labor, and the UFLPA Entity List.

Material counterparties are required to confirm in writing that they have appropriate policies and procedures in place to address modern slavery and human-trafficking risk in their own operations and supply chains, and to notify the Company of any material change in their position.

The Company’s project diligence framework is the central control through which the principal risk identified in clause 4.4 is managed. Every project from which the Company procures, in which it co-invests, or on which it advises a third-party purchaser, is subject to a multi-axis diligence process. The modern-slavery-and-human-rights axis comprises, at minimum:

• (a) confirmation that the project has obtained, documented, and continues to operate under Free, Prior and Informed Consent of the affected indigenous and local communities, in accordance with the standards of the registry under which the project is registered and the expectations of the ICVCM Core Carbon Principles;
• (b) review of the project’s benefit-sharing arrangements, including the identification of community-level recipients of carbon revenue, the proportion of revenue accruing to communities, and the mechanism by which that revenue is paid, audited, and disputed;
• (c) review of the project’s labour practices, including wage levels, payment regularity, working hours, the use of seasonal and migrant labour, the engagement of contractors and sub-contractors, and the presence of contractual or in-kind payment arrangements that could indicate debt bondage;
• (d) verification that no child labour, within the meaning of ILO Conventions Nos. 138 and 182, is engaged on the project;
• (e) review of the project’s grievance mechanism, including its accessibility to affected workers and community members, its operation in local languages, the protection it offers against retaliation, and the published outcomes (if any) of grievances received;
• (f) review of independent verification reports for any adverse findings under the social-safeguards sections of the applicable registry’s monitoring report template;
• (g) where the project is in a jurisdiction subject to a US Department of State Tier 2 Watch List, Tier 3, or Special Case ranking, additional enhanced diligence including, where reasonably practicable, an independent in-country review;
• (h) review of any adverse media, civil-society reporting, or academic literature concerning the specific project, the project’s developer, the project’s verifier, or the geography in which the project operates;
• (i) where the project sources from, or is adjacent to, sectors with elevated forced-labour or child-labour exposure, explicit consideration of cross-contamination risk and of the project’s mitigation measures.

The Company does not procure from, advise on, or otherwise transact in respect of, any project where the project-level diligence identifies an unresolved modern slavery, human-trafficking, forced-labour, or worst-forms-of-child-labour concern, until and unless the concern has been credibly addressed and verified.

The Company’s project diligence outcomes are documented and retained for not less than the period required by applicable anti-money-laundering legislation and in any event for not less than seven years from the conclusion of the relevant engagement.

All members of the Company’s board, officers, employees, and engaged long-term consultants receive training on:

• (a) the indicators of modern slavery and human trafficking, by reference to recognised typologies including the ILO indicators of forced labour;
• (b) the Company’s policies described in clause 6;
• (c) the operation of the project diligence framework described in clause 7;
• (d) the operation of the Whistleblowing and Speaking-Up Policy;
• (e) the personal and corporate criminal-law consequences, in the jurisdictions to which the Company is exposed, of facilitating modern slavery or human trafficking;
• (f) sector-specific developments, including changes in registry safeguards, ICVCM Assessment Framework guidance, and VCMI Claims Code expectations.

Training is delivered at induction and refreshed not less than annually. Records of training delivery and completion are retained.

The Company recognises that the identification of a modern slavery or human-trafficking concern carries with it a responsibility to contribute to its remediation, in a manner consistent with the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises.

Where the Company identifies, or is credibly informed of, a modern slavery, human-trafficking, forced-labour, or worst-forms-of-child-labour concern in connection with:

• (a) the Company’s own operations: the Company will investigate, remediate, and report in accordance with applicable Guernsey law and, where relevant, the law of any other jurisdiction in which the conduct is alleged to have occurred;
• (b) a counterparty or supplier: the Company will engage with the counterparty or supplier, require a remediation plan with verifiable milestones, exercise leverage including by suspending or terminating the relationship where remediation is not forthcoming, and notify competent authorities where required by law;
• (c) a carbon project counterparty: the Company will engage with the project developer, the registry, and where appropriate the validation/verification body, to ensure that the concern is investigated and remediated; the Company will withhold transaction settlement, suspend ongoing advisory engagement, and where the concern is not credibly addressed, terminate the relationship and consider notification to the registry and other relevant bodies.

Concerns may be raised confidentially by any person, including any worker, community member, civil-society organisation, or business partner, by contacting:

• by post: TenTrinity (Guernsey) Ltd, Attention: Speaking-Up Officer, Suite G, St Peter Port House, Sausmarez Street, St Peter Port, Guernsey GY1 2PT, Channel Islands;
• by email: info@tentrinitycarbon.com.

The Company will protect the identity of the reporter and will not tolerate retaliation against any person who raises a concern in good faith.

The Company measures the effectiveness of the steps described in this statement by reference to:

• (a) the proportion of counterparties and suppliers screened at onboarding and at scheduled re-review (target: 100%);
• (b) the proportion of carbon projects subjected to the full diligence framework set out in clause 7 before transaction or advisory engagement (target: 100%);
• (c) the number of diligence outcomes in which a modern slavery, human-trafficking, forced-labour, or child-labour concern was identified, and the proportion that were credibly remediated, suspended, or terminated;
• (d) the proportion of staff who completed the training described in clause 8 within the relevant year (target: 100%);
• (e) the number of concerns raised through the Speaking-Up channel and the manner of their resolution;
• (f) the proportion of carbon projects in the Company’s portfolio that operate under registry safeguards that include explicit FPIC, labour-rights, and grievance-mechanism requirements, and that have current valid validation, verification, and monitoring documentation.

The Company will publish indicative figures against these indicators in subsequent iterations of this statement, in a form that does not compromise the confidentiality of counterparty diligence outcomes.

In the financial year following the period covered by this statement, the Company intends to:

• (a) [•];
• (b) [•];
• (c) [•].

The Company will revisit this statement annually and on the occasion of any material change in the Company’s operations, counterparty relationships, or portfolio.

This statement is made for the financial year ended [•] by the board of directors of TenTrinity (Guernsey) Ltd pursuant to its voluntary adoption of the disclosure expectations set out in clause 3, with the intention that it constitutes a substantive statement of the Company’s position whether or not the Company is at the date of this statement subject to a binding statutory obligation under any of the regimes there identified.

This statement was approved by the board of directors of TenTrinity (Guernsey) Ltd on [•] and is signed below for and on behalf of the board.

• [•]
• Director
• For and on behalf of the Board of Directors
• TenTrinity (Guernsey) Ltd
• Date: [•]