Modern Slavery & Human Trafficking Statement

This statement is made by The Garden in the Machine, Inc. (“TGITM”, “we”, “us”, or “our”) for the fiscal year ending 31 December 2024 pursuant to section 54 of the United Kingdom Modern Slavery Act 2015, the Australian Modern Slavery Act 2018, the California Transparency in Supply Chains Act, and similar legislation. It outlines the steps we take to prevent modern slavery, forced labor, and human trafficking within our business and supply chains.

Last updated: February 14, 2025

Our Business and Structure

TGITM is a U.S.-headquartered technology company that designs, develops, and operates the emergentic.ai platform—an AI agent authoring environment used by storytellers, researchers, and studios worldwide. We operate globally through wholly owned subsidiaries and contractor networks to provide product development, trust & safety, customer success, and professional services. Our workforce is composed primarily of engineers, designers, applied researchers, and creative technologists based in the United States, Canada, the United Kingdom, the European Union, Australia, and Latin America.

Policies and Governance

  • Code of Conduct: All employees, contractors, and suppliers must follow our Code of Conduct, which prohibits forced labor, child labor, harassment, discrimination, and retaliation, and requires compliance with applicable labor laws.
  • Supplier Standards: Vendor contracts include clauses requiring adherence to human rights laws, anti-slavery statutes, and audit cooperation. Higher-risk engagements include explicit flow-down obligations to subcontractors.
  • Reporting Channels: Employees and third parties can confidentially report concerns through our ethics hotline or the emergentic.ai Help Center. We prohibit retaliation against good-faith reporters.

Our Board of Directors and executive leadership receive periodic updates on ESG risks, including modern slavery and human rights topics.

Risk Assessment and Due Diligence

Our operations primarily involve highly skilled digital work, which we assess as low risk for modern slavery. Nonetheless, we conduct risk-based due diligence focused on:

  • Third-party data labeling, content moderation, and voice talent engagements.
  • Vendors located in regions with higher prevalence of labor violations.
  • Facilities procurement (e.g., office services) and hardware supply chains.

Before onboarding a vendor, our Legal, Security, and Finance teams review contractual controls, labor practices, background checks, sanctions screenings, and compliance certifications. We reserve the right to audit suppliers and terminate relationships if violations are identified.

Training and Awareness

All employees receive annual training on our Code of Conduct, whistleblowing procedures, and how to identify indicators of forced labor or trafficking. Teams responsible for procurement, recruiting, and vendor management receive additional guidance on risk signals, contractual safeguards, and escalation paths.

Performance Indicators

  • Percentage of employees and contingent workers who acknowledge the Code of Conduct (target: 100%).
  • Completion rates for responsible sourcing and anti-slavery training.
  • Number of vendors reviewed under enhanced due diligence.
  • Timely remediation of any reported concerns (none substantiated in FY24).

We will continue refining these metrics and publishing progress in future statements.

Future Commitments

  • Expand supplier questionnaires to cover human rights, diversity, and environmental factors.
  • Evaluate additional third-party audit frameworks for higher-risk workflows.
  • Establish a cross-functional working group to review modern slavery risks annually.
  • Publish a summary of remediation steps should any incidents be identified.

Approval

This statement has been approved by the Board of Directors of The Garden in the Machine, Inc. and signed on its behalf.

Date: February 14, 2025
Signed on behalf of The Garden in the Machine, Inc.