Anti-Slavery & Human Trafficking Policy

1. Policy statement

1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes
various forms, such as slavery, servitude, forced and compulsory labour and
human trafficking, all of which have in common the deprivation of a person’s
liberty by another in order to exploit them for personal or commercial gain. We
have a zero-tolerance approach to modern slavery, and we are committed to
acting ethically and with integrity in all our business dealings and relationships
and to implementing and enforcing effective systems and controls to ensure
modern slavery is not taking place anywhere in our own business or in any of our
supply chains.

1.2 We are also committed to ensuring there is transparency in our own business
and in our approach to tackling modern slavery throughout our supply chains,
consistent with our disclosure obligations under the Modern Slavery Act 2015.
We expect the same high standards from all our contractors, suppliers, and other
business partners, and as part of our contracting processes, we include specific
prohibitions against the use of forced, compulsory or trafficked labour, or anyone
held in slavery or servitude, whether adults or children, and we expect that our
suppliers will hold their own suppliers to the same high standards.

1.3 This policy applies to all persons working for us or on our behalf in any capacity,
including employees at all levels, directors, officers, agency workers, seconded
workers, volunteers, interns, agents, contractors, external consultants, third-party
representatives, and business partners.

1.4 This policy does not form part of any employee’s contract of employment, and we
may amend it at any time.

2. Responsibility for the policy

2.1 The board of directors has overall responsibility for ensuring this policy complies
with our legal and ethical obligations, and that all those under our control comply
with it.

2.2 The Chief Executive Officer, (CEO), has primary and day-to-day responsibility for
implementing this policy, monitoring its use and effectiveness, dealing with any
queries about it, and auditing internal control systems and procedures to ensure
they are effective in countering modern slavery.

2.3 Management at all levels are responsible for ensuring those reporting to them
understand and comply with this policy and are given adequate and regular
training on it and the issue of modern slavery in supply chains.

2.4 You are invited to comment on this policy and suggest ways in which it might be
improved. Comments, suggestions, and queries are encouraged and should be
addressed to the compliance manager.

3. Compliance with the policy

3.1 You must ensure that you read, understand, and comply with this policy.

3.2 The prevention, detection and reporting of modern slavery in any part of our
business or supply chains is the responsibility of all those working for us or under
our control. You are required to avoid any activity that might lead to, or suggest,
a breach of this policy.

3.3 You must notify your manager as soon as possible if you believe or suspect that
a conflict with this policy has occurred or may occur in the future.

3.4 You are encouraged to raise concerns about any issue or suspicion of modern
slavery in any parts of our business or supply chains of any supplier tier at the
earliest possible stage.

3.5 If you believe or suspect a breach of this policy has occurred or that it may occur
you must notify your manager as soon as possible. You should note that where
appropriate, and with the welfare and safety of local workers as a priority, we
may give support and guidance to our suppliers to help them address coercive or
exploitative work practices in their own business and supply chains.

3.6 If you are unsure about whether a particular act, the treatment of workers more
generally, or their working conditions within any tier of our supply chains
constitutes any of the various forms of modern slavery, raise it with your

3.7 We aim to encourage openness and will support anyone who raises genuine
concerns in good faith under this policy, even if they turn out to be mistaken. We
are committed to ensuring no one suffers any detrimental treatment as a result of
reporting in good faith their suspicion that modern slavery of whatever form is or
may be taking place in any part of our own business or in any of our supply
chains. Detrimental treatment includes dismissal, disciplinary action, threats, or
other unfavourable treatment connected with raising a concern. If you believe
that you have suffered any such treatment, you should inform the compliance
manager immediately. If the matter is not remedied, and you are an employee,
you should raise it formally using our Grievance Procedure, which can be found
within our employee handbook.

4. Communication and awareness of this policy

4.1 Training on this policy, and on the risk our business faces from modern slavery in
its supply chains, forms part of the induction process for all individuals who work
for us, and regular training will be provided as necessary.

4.2 Our zero-tolerance approach to addressing the issue of modern slavery in our
business and supply chains must be communicated to all suppliers, contractors
and business partners at the outset of our business relationship with them and
reinforced as appropriate thereafter.

5. Breaches of this policy

5.1 Any employee who breaches this policy will face disciplinary action, which could
result in dismissal for misconduct or gross misconduct.

5.2 We may terminate our relationship with other individuals and organisations
working on our behalf if they breach this policy.

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