Modern Slavery and Human Trafficking Statement

Zwinkle is committed to conducting business ethically, transparently, and responsibly. We strongly oppose all forms of modern slavery, forced labour, human trafficking, and exploitation in any part of our business operations or supply chains.

This statement outlines Zwinkle’s ongoing efforts to prevent modern slavery risks and promote human rights across our organisation and business partners.

1. Our Organisation and Business Activities

Zwinkle operates as a global digital platform that connects individuals through online social interaction, dating services, and community engagement features. Our services are supported by technology providers, software development partners, cloud infrastructure vendors, and digital service suppliers worldwide.

We are committed to ensuring our business practices reflect respect for human rights and ethical labour standards across all operational areas.

2. Our Policies and Ethical Standards

Zwinkle maintains strict internal policies that prohibit:

• Forced or involuntary labour

• Human trafficking or exploitation

• Child labour or illegal employment practices

• Unethical recruitment or labour abuse

All employees, contractors, and partners are expected to comply with these ethical standards and operate in accordance with applicable labour and human rights laws.

3. Due Diligence and Supplier Responsibility

Zwinkle works with trusted technology and service providers. We take reasonable steps to ensure our suppliers and partners:

• Follow ethical labour practices

• Respect international human rights standards

• Maintain transparent employment policies

• Avoid forced labour or exploitation risks

Where appropriate, Zwinkle may review supplier compliance and request confirmation of ethical practices.

4. Risk Assessment and Prevention

As a digital technology company, Zwinkle generally operates in low physical labour supply chain environments. However, we recognise potential risks associated with outsourced services, software development, and third-party vendors.

To reduce risk, Zwinkle:

• Carefully evaluates business partners

• Works with reputable service providers

• Maintains contractual compliance requirements

• Monitors operational relationships when necessary

5. Staff Awareness and Training

Zwinkle promotes awareness of ethical business conduct among team members. Staff are encouraged to:

• Report suspected human rights violations

• Follow ethical sourcing and hiring practices

• Maintain transparency in professional conduct

6. Reporting Concerns

Zwinkle encourages employees, partners, and users to report concerns relating to unethical practices, labour abuse, or human exploitation.

Reports can be submitted confidentially through our support channels or compliance contact.

7. Continuous Improvement

Zwinkle remains committed to reviewing and improving policies, supplier standards, and ethical safeguards to help prevent modern slavery risks in our business operations.

8. Approval

This statement is reviewed and approved by Zwinkle’s management and reflects our commitment to ethical and responsible business conduct.