MINML Ltd
Modern Slavery Statement
Introduction
MINML Ltd ("MINML" or the "Company") is committed to preventing modern slavery and human trafficking in all forms, including forced labour, human trafficking and child labour, across our business and any current or future supply chains. Whilst the Company is under no statutory obligation to produce a Modern Slavery Statement, this statement is published in accordance with our commitment to transparency and responsible business conduct and will be reviewed and updated annually.
Our Organisation and Current Operations
MINML is a technology company providing AI-driven mineral prospectivity mapping and drill-targeting analytics. Our current operations are principally software and data-based, with no on-the-ground exploration or extraction activities undertaken to date.
Anticipated Future Operations
MINML intends to expand its activities to include on-ground mineral exploration, which may include work conducted in jurisdictions with elevated risk of modern slavery, weaker labour protections or less mature regulatory oversight (including in developing economies). We recognise that field-based exploration activities, and the contractors, labour agencies and local suppliers associated with them, carry materially higher modern slavery risk than our current software business. This statement is issued proactively to establish our policy framework ahead of that expansion and will be substantively expanded once field operations commence.
Our Policies
As we grow, MINML commits to maintaining:
- An Anti-Slavery and Human Trafficking Policy, applicable to all employees, directors, contractors and business partners.
- A Supplier and Contractor Code of Conduct, prohibiting forced, bonded, or child labour, and requiring fair recruitment, wages and working hours.
- A Whistleblowing Policy, enabling employees and third parties to report concerns confidentially and without retaliation.
Due Diligence and Risk Management
Before commencing any on-ground exploration activity, MINML commits to:
- Conducting risk-based due diligence on the jurisdiction, local labour market conditions and any exploration partners, contractors, or labour suppliers engaged.
- Undertaking enhanced due diligence in jurisdictions identified as higher-risk (e.g. per recognised indices such as the Global Slavery Index).
- Including anti-slavery clauses in contracts with exploration partners, drilling contractors and local suppliers.
- Requiring on-site partners to demonstrate compliance with local labour law and international labour standards (including International Labour Organisation conventions) prior to engagement.
Training
Relevant staff and management involved in supplier selection, contracting and field operations will receive training on identifying and responding to modern slavery risk indicators before any field programme begins.
Monitoring and Effectiveness
MINML will assess the effectiveness of these measures through periodic review of supplier and contractor arrangements once field operations commence and will report on findings in future statements.
Looking Ahead
This statement reflects MINML's position prior to the commencement of field-based exploration. As operations develop, we will update this statement to reflect actual supply chains, specific jurisdictions of operation, due diligence outcomes and any remedial actions taken.
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