Modern Slavery and Human Trafficking Policy

Modern slavery is a crime resulting in an abhorrent abuse of the human rights of vulnerable workers. It can take various forms, such as slavery, servitude, forced and compulsory labour and human trafficking. The Company has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all our business dealings and relationships. The company takes reasonable steps to ensure slavery and human trafficking are not taking place in any business or organisation that has any sort of business relationship with our company.

This policy applies to all individuals working for the Company or on the Company’s behalf in any capacity, including employees, directors, officers, agency workers, contractors, consultants, and business partners.

Due Diligence

The Company has zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors to comply with our values.

As part of our initiative to identify and mitigate risk the Company has in place systems to encourage the reporting of concerns and the protection of whistleblowers.

Our supply chain providers are always with a UK or EU provider, and we expect these entities to have suitable anti-slavery and human trafficking policies and processes.


Training and Communication

The management team are responsible for compliance within their respective departments and in their supplier relationships and have been trained accordingly.

There is a Company induction where our policies, procedures and expectations are outlined.

Our effectiveness in combatting slavery and human trafficking

The Company uses the following key performance indicators to measure how effective we have been
to ensure that slavery and human trafficking is not taking place in any part of our business or supply
chains:

– Use of labour monitoring, right to work documentation and payroll audits

– We maintain a level of communication and personal contact with the next link in the supply
chain to ensure their understanding of, and compliance with, our expectations.

– Use of labour monitoring, right to work documentation and payroll audits

We regularly review supply chain policies, codes of conduct and our working practices to
show commitment.

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and
constitutes the Company’s slavery and human trafficking statement. This statement has been
approved by the organisations Board of Directors, who will review and update it annually.

Breach of Policy

Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct. The Company may terminate its commercial relationship with suppliers, contractors, and other business partners if they breach this policy and/or are found to have been involved in modern slavery.