Modern Slavery and Human Trafficking Statement

Responsibility for the organisation's anti-slavery initiatives is as follows:

Policies:

• Recruitment – we operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
• Whistleblowing – our whistleblowing policy ensures that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisal.
• Health and Safety – this policy sets out our approach to ensure we provide a healthy working environment for our staff and contractors that work out of our premises.

Investigations/due diligence:

We:

1. risk assess all new suppliers using the Global Slavery Index and ask them to certify that they have taken steps to eradicate modern slavery within their own organisation and supply chain;
2. notify all existing suppliers of our expectations and their obligations in relation to the prohibition of modern slavery;
3. incorporate anti-slavery and human trafficking obligations into procurement agreements and subcontracting arrangements on a risk assessed basis;
4. include appropriate measures in our due diligence processes for sourcing suppliers, subcontractors and acquisitions on a risk assessed basis;
5. provide training to relevant Group employees to ensure a high level understanding of the risks of modern slavery and human trafficking; and
6. where appropriate we will include reference to the Modern Slavery Act 2015 in our policies and procedures.

Training:

All employee Modern Slavery training has been adopted including actions required when any signs are spotted.

Relevant policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Whistleblowing policy: The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can report these directly to the CEO.
• Employee code of conduct: The organisation's code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
• Recruitment policy: The organisation uses only specified, reputable employment agencies to source labour.

Due diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation's due diligence and reviews include:

• mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
• evaluating the modern slavery and human trafficking risks of each new supplier;
• reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
• conducting supplier audits or assessments through the organisation's own staff which have a greater degree of focus on slavery and human trafficking where general risks are identified;
• creating an annual risk profile for each supplier;
• invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship

Performance indicators

The organisation has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the organisation is:

• requiring all staff to have completed training on modern slavery by October 2021

Training

The organisation requires all staff within the organisation to complete training on modern slavery.

The organisation requires all staff to complete an online training course by October 2021. The organisation's modern slavery training covers:

• how to identify the signs of slavery and human trafficking;
• what initial steps should be taken if slavery or human trafficking is suspected;
• how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
• what external help is available, for example through the Modern Slavery Helpline;

Board approval

This statement has been approved by the organisation's CEO and Senior Management Team, who will review and update it annually.

Reviewed November 2022.