Modern Slavery and Human Trafficking Policy

Purpose The Group is dedicated to upholding ethical standards and integrity in all its business practices. We are committed to preventing all forms of modern slavery, human trafficking, forced labour, and exploitation. As a responsible employer we recognise our responsibility to combat modern slavery within our operations and supply chains. This policy outlines our commitments to prevent modern slavery and ensure transparency in our business practices. Scope 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. We expect all individuals and organisations associated with us to uphold our commitment to anti-slavery and to adhere to applicable laws and ethical standards. This policy does not form part of any employee’s contract of employment and we may amend it at any time. Definitions Modern Slavery: Refers to slavery, servitude, forced and compulsory labour, and human trafficking as defined by the UK Modern Slavery Act 2015. Human Trafficking: Involves the recruitment, transportation, transfer, harbouring, or receipt of people by improper means (force, fraud, or coercion) for the purpose of exploitation. Policy Statement

1. Commitment to Combatting Modern Slavery

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 combat modern slavery anywhere in our own business or in any of our supply chains. We believe in treating all individuals with respect, ensuring fair labour practices across our operations and promoting fair labour practices within our supply chain.

2. Risk Assessment and Due Diligence

We conduct risk assessments of our business operations and supply chains, whilst also supporting and encouraging our suppliers to identify and mitigate potential risks related to modern slavery.

3. Supplier Conduct

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. We assess suppliers on their labour practices and reserve the right to audit their compliance with our standards. Non-compliance may result in the termination of business relationships.  

4. Training and Awareness

We provide mandatory training on modern slavery and human trafficking for senior managers annually. Training focuses on recognising the signs of exploitation and reporting concerns appropriately.

5. Reporting and Whistleblowing

The Group encourages employees, suppliers, and stakeholders to report any concerns related to modern slavery to their line manager, business contact or our confidential whistleblowing hotline. Reports are thoroughly investigated, and corrective action is taken when necessary.

6. Monitoring and Continuous Improvement

We continuously monitor and evaluate our business practices to identify and mitigate modern slavery risks. The Group commits to reviewing its anti-slavery policies and procedures annually to ensure alignment with best practices and legal requirements.

7. Transparency and Reporting

As part of our commitment to transparency, from 2025 we will publish an annual Modern Slavery Statement, detailing the actions taken to prevent and address modern slavery risks within our operations and supply chain. This statement will be approved by our Board of Directors and will be publicly available on our website. Compliance with the UK Modern Slavery Act 2015 The Group adheres to the UK Modern Slavery Act 2015 and is committed to transparent reporting on modern slavery risks and prevention. Board Responsibility Our Board of Directors has overall responsibility for ensuring this policy’s implementation and effectiveness. They support and oversee our commitment to maintaining an ethical and compliant workplace. Policy Review This policy will be reviewed annually by the Board to ensure continued relevance and effectiveness in preventing modern slavery within our business and supply chains. Approval This policy is approved by the Board of Directors.