Modern Slavery Statement

Effective Date: 05/28/2024

Welcome to The Word Savant, the trade name of Novoguard LLC, a business incorporated in the state of Wyoming, USA. At The Word Savant, we are committed to upholding the highest standards of ethical conduct and integrity in all aspects of our operations. This Modern Slavery Statement outlines our commitment to preventing modern slavery and human trafficking within our supply chains and business operations across the United States (US), European Union (EU), Middle East, and Asia.

1. Our Commitment

The Word Savant unequivocally condemns all forms of modern slavery, including human trafficking, forced labor, and any other practices that exploit individuals. We are dedicated to ensuring that our business operations and supply chains are free from such unethical practices. This commitment is embedded in our company values and is integral to our business strategy.

2. Structure and Operations

The Word Savant operates as an online consumer review platform and health and wellness directory, facilitating the sharing of experiences related to aesthetic medical clinics. Our primary operations include:

• Platform Management: Maintaining and enhancing our website www.thewordsavant.com to ensure a seamless user experience.

• Content Moderation: Ensuring that all user-generated content complies with our Content Policy and ethical standards.

• Marketing and Communications: Promoting our platform through various channels while adhering to ethical marketing practices.

• Customer Support: Providing assistance and support to our users to maintain a trustworthy community.

Our operations extend across the US, EU, Middle East, and Asia, enabling us to serve a diverse and global user base.

3. Supply Chains and High-Risk Areas

While The Word Savant primarily operates online and does not engage in traditional supply chains, we recognize that our business activities may involve various internal teams and in-house departments, such as:

• IT and Hosting Services: Our in-house team manages our website infrastructure to ensure its reliability and security.

• Content Moderation Team: An in-house team dedicated to the moderation and review of user-generated content, ensuring compliance with our policies and ethical standards.

• Marketing and Advertising Teams: Internal teams responsible for promoting our services and managing advertising campaigns.

High-Risk Areas:

Given our international presence, we acknowledge that certain regions may pose higher risks for modern slavery and human trafficking. These include:

• Asia (especially countries with known labor exploitation issues)

• Middle East (regions with high migrant worker populations)

• Certain sectors within the EU and US where subcontracting and temporary labor are prevalent

We continuously assess these risks to ensure that our partnerships and operations do not contribute to any form of modern slavery.

4. Policies to Combat Modern Slavery

To demonstrate our commitment, The Word Savant has implemented the following policies:

• Anti-Slavery and Human Trafficking Policy: A comprehensive policy outlining our stance against modern slavery, including guidelines for ethical conduct and internal expectations.

• Code of Conduct: Standards for all employees and partners to ensure ethical behavior and compliance with anti-slavery laws.

• Supplier Code of Conduct: Requirements for any third-party service providers to adhere to ethical labor practices and comply with applicable laws.

These policies are regularly reviewed and updated to reflect best practices and evolving legal requirements.

5. Due Diligence Processes

The Word Savant employs robust due diligence processes to identify and mitigate risks related to modern slavery:

• Internal Assessments: Conducting thorough evaluations of our internal processes and departments to ensure they comply with our Anti-Slavery Policy.

• Contractual Obligations: Including clauses in our contracts that require any external partners to adhere to anti-slavery laws and ethical labor practices.

• Risk Assessments: Regularly assessing our operations to identify potential vulnerabilities to modern slavery.

• Audits and Monitoring: Periodically auditing our internal teams and any external partners to ensure compliance with our policies.

These measures help us maintain a transparent and accountable operational environment, even within our online operations.

6. Training and Awareness

To ensure that our commitment is upheld across the organization, The Word Savant provides regular training and awareness programs:

• Employee Training: Educating our team members about modern slavery, recognizing potential signs, and understanding their roles in preventing it.

• Manager and Execution Team Training: Specialized training for managers and the execution team to oversee and enforce anti-slavery practices effectively.

• Awareness Campaigns: Promoting awareness within our community about the importance of ethical labor practices and the impact of modern slavery.

By fostering a culture of awareness and responsibility, we empower our employees and partners to actively contribute to our anti-slavery efforts.

7. Reporting and Whistleblowing

The Word Savant encourages all stakeholders to report any concerns related to modern slavery or unethical practices:

• Whistleblowing Channels: Providing confidential and secure channels for employees, suppliers, and users to report suspected cases of modern slavery.

• No Retaliation Policy: Ensuring that individuals who report concerns in good faith are protected from retaliation or adverse consequences.

• Responsive Action: Promptly investigating all reports and taking appropriate action based on our findings.

These mechanisms ensure that potential issues are addressed swiftly and effectively, maintaining the integrity of our platform.

8. Continual Improvement

The Word Savant is committed to continuously enhancing our efforts to combat modern slavery:

• Regular Reviews: Periodically reviewing and updating our Anti-Slavery Policy and related procedures to incorporate new insights and best practices.

• Stakeholder Engagement: Collaborating with industry bodies, NGOs, and other stakeholders to stay informed about emerging trends and effective strategies in combating modern slavery.

• Performance Metrics: Establishing and monitoring key performance indicators (KPIs) to measure the effectiveness of our anti-slavery initiatives.

Through ongoing evaluation and improvement, we strive to uphold the highest standards of ethical conduct and labor practices.

9. Accountability and Governance

Our leadership team plays a pivotal role in ensuring compliance and fostering a culture of accountability:

• Senior Management Oversight: Senior executives are responsible for overseeing the implementation and effectiveness of our Anti-Slavery Policy.

• Dedicated Team: Assigning specific roles and responsibilities to team members to manage and monitor our anti-slavery efforts.

• Board Reporting: Managers and the execution team regularly report to the board of directors on our progress and challenges in combating modern slavery.

This structured governance ensures that our commitment is embedded at all levels of the organization.

10. Legal Compliance

The Word Savant adheres to all relevant modern slavery and data protection laws across the regions we operate in, including but not limited to:

• United States: Compliance with the Trafficking Victims Protection Act (TVPA) and other relevant federal and state laws.

• European Union: Adherence to the EU Anti-Trafficking Directive and GDPR.

• Middle East: Compliance with local labor and anti-trafficking regulations.

• Asia: Adherence to country-specific laws such as Singapore PDPA, Japan APPI, and China PIPL.

By staying informed and compliant with these laws, we ensure that our operations respect human rights and ethical labor standards globally.

11. Contact Information

For any questions, concerns, or reports regarding our Modern Slavery Statement or our efforts to combat modern slavery, please contact us at:

• Email: TBD

• Mailing Address: Novoguard LLC, 30, North Gould Street, Sheridan, WY.