KLASHA’S MODERN SLAVERY STATEMENT

INTRODUCTION

This statement applies to Klasha, Inc. and Klasha Technologies Limited and its subsidiaries (together, “Klasha”). At Klasha we take seriously our responsibility to ensure that our business is conducted in an ethical way and we actively address important social issues.

As part of this process, we recognize the harmful impact that Modern Slavery and Human Trafficking has on individuals and the society and we are committed to help prevent these illegal practices. We also expect the same high standards from all of our contractors, and other business partners

OUR ORGANIZATION

Klasha is a technology company in partnership with licensed payment service providers, offering commerce payment solutions across Africa. We make it easy for merchants to accept credit and debit card payments online from users or customers.

SUPPLY CHAIN AND PARTNERS DUE DILIGENCE

Klasha has adopted a risk based approach in reviewing its supply chain, whilst ensuring that this approach is in compliance with legal requirements. Due to the technological nature of the services provided by Klasha, its supply chains are relatively straightforward.

In addition, as part of our initiative to identify and manage slavery and human trafficking risk, we continue to build and improve our system to better (i) identify, assess and monitor potential higher risk areas in our supply chains; and (ii) mitigate the risk of slavery and human trafficking occurring in our supply chains through enhanced contract terms controls (to the extent appropriate and obtainable).

OUR POLICIES

This sets out our position with respect to human rights and modern slavery and sits alongside our Employment Manual, Health and Safety Policy, Global Human Rights Statement and the Global Third Party Code of Conduct.

i. Child Labour: Klasha will not use child labour and will comply with all relevant laws in this regard. We do, however, support legitimate workplace internship and other similar programs that comply with applicable laws and regulations.

ii. Modern Slavery: Klasha will not use forced, bonded or involuntary labour, and workers are not required to lodge ‘deposits’ or identity paper with the Company and can leave after giving reasonable notice, with all wages owed to be paid. We have zero-tolerance approach to human trafficking.

iii. Health, Safety and Hygiene: All Klasha employees will work in an environment that is both safe and healthy.

iv. Discipline: Klasha prohibits physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation. Disciplinary and grievance procedures are clearly documented and communicated to all employees in our Employment contract. All disciplinary, measures of a serious nature are recorded and acted upon swiftly in line with our Employee Handbook and relevant laws.

v. Working Hours: Klasha will ensure that working hours are reasonable and comply with the law and industry standards.

vi. Equality of Treatment: Klasha is fully committed to eliminating discrimination in recruitments, training and working conditions on grounds of race, colour, sex, age, religion, political opinion, national extraction, sexual orientation, disability or social origin and to promoting equality of opportunity and treatment.

vii. Employment terms: Klasha will provide written and clear contract which details the terms and conditions or its staff employment. We will ensure that work performed by employees is on the basis of recognized employment law and practice.

viii. Remuneration: Klasha will, at a minimum set by the law, provide wages and benefits that meet national standards. We will provide employees with clear written information on their pay and conditions. We are committed to equal pay and benefits for men and women for work of equal value.

IMPLEMENTATION

Klasha Board of directors and senior management shall have overall responsibility for implementing the MSA Policy and the objectives considered in this statement. We will monitor progress of our efforts, and issues (should they arise) will be considered by Klasha’s Board of Directors who will decide on the immediate and appropriate action to be taken.

EFFECTIVENESS

We continue to monitor our performance against the following in order to gauge how effective we are in dealing with the risk of slavery and human trafficking in our business or suppliers/partners:

i. Implementation of the Modern Slavery Policy

ii. Developing a system for supply chain identification, including, where appropriate adding slavery and human trafficking enquiries and controls to our procurement policies.

iii. Where appropriate, asking specific questions on modern slavery in our terms with third parties for the supply of goods and services.

APPROVALS

The statement was approved by the Board of Directors of Klasha, Inc. and Klasha Technologies Limited.