Version History Table

1. OVERVIEW AND HOW WE DEFINE MODERN SLAVERY
   
   1.1. The purpose of this policy is to set out our responsibilities and to provide a framework for all individuals working for us, or on our behalf, to uphold our commitment. It is designed to ensure we comply with our legal obligations under the UK’s Modern Slavery Act 2015 and to implement effective systems and controls to prevent modern slavery from taking place anywhere within our own business or our supply chains. This includes any future requirements in relation to reporting or due diligence under Section 54 (“Transparency in Supply Chains”) of the Modern Slavery Act.
   
   1.2. Slavery, forced labour, servitude, and human trafficking are types of ‘Modern Slavery’ – criminal activity that deprives victims of their liberty and usually involves financial and other exploitation.
   
   1.3. We conduct our business fairly, ethically and with respect to fundamental human rights. We are committed to the prevention of all forms of Modern Slavery, both in our business and in our supply chains. We will not tolerate it.
   
   1.4. You must read and comply with this policy if you work for, or on behalf of us in any capacity. This includes employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.
   
   1.5. The policy extends to all our business dealings and to the full extent of our supply chains, wherever they may be located. All suppliers are expected to adhere to the principles of this policy as a condition of doing business with us.
   
   1.6. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct.
   
   1.7. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy. Suppliers who are found to be non-compliant or knowingly involved in modern slavery will have their contracts terminated, and we may seek legal remedies.
   
   1.8. If you are an employee, this policy does not form part of your employment contract, and we may update it at any time.
   
   2. PREVENTING MODERN SLAVERY IN OUR BUSINESS
   
   2.1. We conduct robust identity and right-to-work checks for all direct employees to prevent trafficking and illegal working. We will not use any recruitment agency or labour provider that is not compliant with all relevant legislation. We will not partner with any agency that charges fees to work-seekers.
   
   2.2. We give every employee a written employment contract. Wages are paid directly into a personal bank account in the employee’s name. We will never retain an employee’s or worker’s original identity documents. We will adopt due diligence to prevent, mitigate, and remediate modern slavery in our business and supply chains in line with the requirements of the Modern Slavery Act (2015).
   
   3. IF YOU ARE ONE OF OUR SUPPLIERS
   
   3.1. If you supply us with goods or services, you must assess your business and supply chains and confirm to our Directors that you:
   
   Comply with your legal obligations, in relation to Modern Slavery; and
   
   Are committed to ensuring there is no Modern Slavery taking place in your business, or in any of your supply chains.
   
   You may also be asked to provide a copy of your Modern Slavery policy.
   
   3.2. If you breach this policy or are found to have Modern Slavery in your business, or knowingly in your supply chain, we may terminate our contract with you and pursue legal remedies against you.
   
   4. SUPPLY CHAIN DILLIGENCE
   
   4.1. We recognise that our greatest exposure to Modern Slavery risk lies within our supply chain. Therefore, we have established a comprehensive, risk-based due diligence program to identify, prevent, and mitigate these risks. This program involves a multi-stage process that begins with mapping our supply chain to understand its composition and identify high-risk areas. As part of our supplier onboarding process, all potential new suppliers must complete a detailed self-assessment questionnaire covering their governance, policies, risk management, and procedures related to Modern Slavery. Based on this information and our own risk assessment, we will conduct further investigations, which may include desktop audits or on-site inspections, before approving a new supplier. This due diligence is not a one-time event; it is an ongoing process of monitoring and verification throughout the supplier relationship.

Due Diligence Process
We will adopt a risk-based approach to due diligence to prevent, mitigate, and remediate modern slavery in our business and supply chains.

Supply Chain Mapping & Risk Assessment
We will map our supply chains to identify our direct (Tier 1) suppliers and work to gain visibility of our indirect suppliers (Tier 2 and beyond). We will conduct regular risk assessments to identify the parts of our business and which suppliers are at highest risk, considering sector, geographical location, commodity, and the nature of the workforce.

Supplier Vetting & Contractual Obligations
Modern slavery risk will be a factor in our supplier selection process. As part of our contracting process, we will require suppliers in high-risk areas to:
• Confirm their compliance with the Modern Slavery Act 2015.
• Provide evidence of their own risk assessments and due diligence processes.
• Agree to our Supplier Code of Conduct.
• Accept contractual clauses that grant us the right to conduct audits and require them to hold their own sub-contractors to the same standards

Audits & Verification
For suppliers identified as high-risk, we will undertake a programme of enhanced due diligence, which may include completing detailed assessments (such as the Modern Slavery Assessment Tool), and conducting periodic on-site audits, either by ourselves or by a qualified third party.

Remediation
We are committed to taking appropriate care in selecting our business partners and personnel to mitigate the risk of bribery being committed on our behalf. We conduct risk-based due diligence on our associated persons. For employees, this includes pre-employment screening, with enhanced background checks conducted for individuals being hired into roles identified as high-risk, such as senior management, sales, or procurement. For third-party associated persons, such as agents, consultants, distributors, and joint venture partners, we conduct a level of due diligence that is proportionate to the risk they present. This may range from basic checks for low-risk suppliers to extensive investigations for high-risk agents operating in high-risk markets. We require anti-bribery clauses in our contracts with all third parties, and we engage in ongoing monitoring of these relationships to ensure continued compliance.

5. IF YOU ARE AN EMPLOYEE OR A WORKER PROVIDING SERVICES FOR US

5.1. You must immediately report any suspicions of Modern Slavery in our business or supply chains to our Directors. Our Directors will investigate and report to our Directors within a reasonable time, on actions which may require to be taken.

5.2. Facilitation Payments and Kickbacks
You will not suffer any detrimental treatment as a result of reporting any genuine concerns, raised in good faith, under this policy. This applies, even if after investigation, they are found to be mistaken. If you believe that you have suffered any such treatment, you should immediately tell our Directors and, if you are an employee, refer to our Grievance and Whistleblowing Policies.

6. COMPLIANCE, MONITORING & KPI’S

6.1. We will measure the effectiveness of our actions against modern slavery by tracking a number of Key Performance Indicators (KPIs). These will be reviewed annually by senior management and used to drive continuous improvement.

Our KPIs will include, but are not limited to:

– Percentage of staff who have completed mandatory modern slavery training.
– Percentage of high-risk suppliers who have been audited.
– Number of modern slavery concerns raised, investigated, and remediated.
– Time taken to implement corrective actions for any identified issues