Modern Slavery & Human Trafficking Policy

1 Statement

We are committed to ensuring that our business, its direct supply chain and business partnerships are free of modern slavery and human trafficking and will not hesitate to perform due diligence if necessary.

Any evidence or suspicion of the above occurring in any contact organisation or contact individual or group of individuals will immediately result in us submitting a report to the relevant authorities and suspending any interaction between ourselves and the party concerned until a satisfactory outcome has been reached.

We acknowledge our responsibilities in relation to tackling modern slavery and human trafficking and are committed to complying with the provisions of the Modern Slavery Act 2015.

We adhere strictly to the standards required in relation to our responsibilities under all relevant employment legislation.

2 Definition of Modern Slavery

We consider that modern slavery encompasses:

• Human trafficking.
• Forced work through mental or physical threat.
• Being owned or controlled by an employer through mental or physical abuse or the threat of abuse.
• Being dehumanised, treated as a commodity or being bought or sold as property.
• Being physically constrained or having restrictions placed on freedom of movement.

3 Our Intent

We will not enter into a business relationship with any party which knowingly supports or is found to have involved itself in any aspect of the above, nor will we do so ourselves.

4 Our Expectations of Employees & Others

We expect all employees, agents, contractors, subcontractors, consultants, business partners and any other parties (including individuals, partnerships and bodies corporate) associated with us or any of our subsidiaries also to have zero tolerance towards modern slavery. We reserve the right to request access to the policies of all others in this regard.

5 Due Diligence Process

We ensure that modern slavery is not taking place in our organisation by taking the following steps:

The geographical scope of our operations is primarily limited to the UK & Ireland and nature of our work makes modern slavery or human trafficking an unlikely event.
However, we implement the following measures:

• We directly employ our staff.
• We conduct 'right to work diligence'.
• Where we operate outside of these the UK and Ireland and we directly employ our staff we comply with all local laws.
• Where possible we build long-standing relationships with local suppliers and we validate that these entities have suitable anti-slavery and human trafficking policies in place.
• We have a system in place to encourage the reporting of concerns.

6 Measures

The following measures demonstrate our effectiveness in ensuring that modern slavery does not take place in any part of our business:

• Right to work checks completed at recruitment stage and any suspicions by the interview panel regarding modern slavery documented and followed up.
• Ensure minimum employment age is adhered to, in line with relevant legislation.
• Always apply national minimum wage thresholds, in line with the relevant legislation.

7 Reporting Concerns & Reviewing

All of the parties listed in section 4 must report any and all concerns to HR or, in the case of non-employees, their normal point of contact within the Company, or otherwise in accordance with the Company’s Whistleblowing Protection Policy.