Policy Against Modern Slavery and Human Trafficking

1.1 Overview and Purpose

Mongol ID A Limited Liability Company ("MID" or "the Company"), incorporated under the laws of Mongolia, with its principal place of business at MID office, 17B, Manlaibaatar Damdinsuren's Street, 13th sub-district, 18th khoroo, Bayanzurkh District, Ulaanbaatar, Mongolia, is committed to conducting business ethically, responsibly, and with integrity.

MID recognises that communities, economies, and businesses thrive when workers' rights are protected. Treating workers of all types (e.g., employees, contractors, students, migrant workers, temporary workers, and others) with dignity and respect is a fundamental component of the Company's commitment to responsible corporate citizenship.

This Modern Slavery Policy establishes MID's commitment to preventing modern slavery, forced labour, human trafficking, child labour, and any form of exploitation within:

• Our business operations
• Our supply chains
• Our business relationships

The Company maintains a zero-tolerance approach to modern slavery and human trafficking and will not knowingly engage with organisations involved in forced labour, human trafficking, or exploitative employment practices.

1.2 Objectives

The objectives of this Policy are to:

• Define the standards, expectations, and requirements that MID employees and Suppliers must follow to prevent modern slavery and human trafficking in MID's business operations, whether overseen directly by MID or indirectly through the operations of Suppliers engaged to support its business.
• Define how MID will make efforts to avoid, detect, and eradicate modern slavery and human trafficking from the Company's or our Suppliers' operations.

This Policy will help MID meet applicable legal obligations under the laws of Mongolia, including but not limited to:

• The Constitution of Mongolia
• On Labor Law of Mongolia
• On Combating Human Trafficking
• On Children's Right Law of Mongolia
• Criminal Code of Mongolia
• Other applicable laws and regulations

This policy supports compliance with international human rights standards and reflects the principles of the UK Modern Slavery Act 2015 (Section 54 - Transparency in Supply Chains), even where not legally required.

1.3 Scope

This policy applies to:

• All employees, directors, and contractors of Mongol ID
• Suppliers, vendors, consultants, and business partners
• Any third parties acting on behalf of Mongol ID

Compliance with this policy is a condition of doing business with Mongol ID.

2.1 Expectations

MID will not tolerate the use of forced labour, child labour, or human trafficking by any employee or Supplier in the operation or support of our business or the provision of our services.

2.2 Prohibited Practices

No MID employee, Supplier, or partner will:

• Participate in the trading or coerced transport of people for exploitation
• Engage in or assist sexual exploitation
• Use forced, bonded, or involuntary labour
• Retain or confiscate personal identity or immigration documents
• Restrict a worker's freedom of movement
• Employ individuals below the legal working age

2.3 Accountability and Management

MID managers are responsible for ensuring that employees who report to them, directly or indirectly, comply with this Policy and complete any certification or training required.

MID has established accountability standards and monitoring procedures to ensure that the requirements identified in this Policy are followed by MID management, employees, and Suppliers.

2.4 Training

MID provides relevant employees with training on modern slavery and human trafficking. Upon request, MID may provide suppliers with a framework to assess their operational compliance with anti-slavery and anti-trafficking requirements.

All MID employees, suppliers, and third parties must fully and promptly cooperate with internal and external auditors and investigators and must respond truthfully to requests for information or documentation.

2.5 Our Commitment

MID is committed to:

• Acting ethically and transparently in all business dealings
• Implementing effective systems and controls to mitigate modern slavery risks
• Respecting internationally recognised human rights
• Promoting fair employment practices

We will not knowingly engage with organisations involved in forced labour, human trafficking, or exploitative employment practices.

To minimise risks related to modern slavery, Mongol ID:

3.1 Supplier Due Diligence

• Conducts appropriate checks before onboarding suppliers
• Evaluates risks based on geography, sector, and service type
• Requires suppliers to comply with applicable labour and human rights laws

3.2 Contractual Safeguards

• Includes contractual clauses requiring compliance with anti-slavery laws where appropriate
• Reserves the right to terminate relationships where violations occur

3.3 Ongoing Monitoring

• Periodically reviews supplier practices
• Investigates credible concerns or allegations promptly

Any MID employee, Supplier, or other entity or individual providing goods or services to or on behalf of MID who has knowledge or information regarding conduct that may violate this Policy must report the information to the MID Legal, Compliance, or Human Resources function.

MID operates under a NO RETALIATION policy. This means that no person will be retaliated against for making a report in good faith. The Company will use its best efforts to protect privacy and maintain confidentiality where permitted by law.

• Any MID employee who fails to cooperate with an audit or investigation related to this Policy, including hiding, deleting, or destroying information, restricting investigator access, or providing false information, may be subject to disciplinary action up to and including dismissal, subject to applicable law.
• Any MID employee who fails to comply with this Policy will be considered in breach of their employment agreement and may be subject to disciplinary action, including termination.
• Employees or Suppliers who fail to report actual or suspected violations of this Policy may also be deemed in violation of this Policy, as permitted by applicable law.
• Compliance with this Policy is a mandatory condition of doing business with MID. MID will terminate its agreement with any third party engaged in modern slavery or human trafficking.
• Violators may also be subject to civil and criminal penalties under applicable Mongolian law.

The following are potential indicators designed to assist employees when observing MID or Supplier operations:

6.1 Work and Living Conditions

• Not free to leave or come and go as they wish
• Unpaid, paid very little, or paid only through tips
• Works excessively long or unusual hours
• Not allowed breaks or subject to unusual work restrictions
• Owes a large debt and appears unable to pay it off
• Recruited through false promises related to work

6.2 Poor Health or Abnormal Worker Behaviour

• Appears fearful, anxious, depressed, submissive, tense, or paranoid
• Avoids eye contact
• Lacks medical care
• Appears malnourished

6.3 Lack of Control

• Not in control of personal money
• No financial records or bank account
• Not in possession of personal identification documents
• Not permitted to speak for themselves

This Modern Slavery Policy is approved by the management of Mongol ID LLC and reflects the company's commitment to ethical business conduct and prevention of modern slavery in all forms.

MONGOL ID LLC

Appendix No. 1 to Order No. B-04/26 of the CEO dated 09 February 2026