Modern Slavery and Anti-Trafficking Policy

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 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 and illegal child labour is not taking place anywhere in our own business or in any of our supply chains.

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 of 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 standard.

We have a separate modern slavery and anti-trafficking policy that applies to those individuals who work for the company including those working in the capacity of employee through to consultant.

This is our public statement of our policy and incorporates our commitment to preventing modern slavery and human trafficking in its business operations and supply chains.

We undertake the following measures to prevent modern slavery and trafficking:

• Supplier Vetting: Conducting background checks and audits on new and existing suppliers.
• Contractual Obligations: Requiring suppliers and partners to commit to anti-slavery practices in their operations.
• Risk Assessments: Regularly reviewing operations to identify high-risk areas.

Management of the company are responsible for:

• Implementing and communicating this policy to all employees, workers and relevant stakeholders.
• Implementing regular training on the issue of modern slavery in supply chains.
• Conducting risk assessments to identify and address areas of potential exposure to modern slavery.
• Monitoring supplier compliance with anti-slavery commitments.

Employees and workers of the company are responsible for:

• Familiarising themselves with this Company policy and reporting any concerns regarding modern slavery or human trafficking.
• Participating in training sessions as required.

Failure to comply with this policy may result in disciplinary actions (in respect of employees and workers), termination of contracts, or legal consequences (in respect of other parties) as applicable.

How to Raise a Concern

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is of paramount importance.

Should there be any concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier, this should be reported to the Chief Financial Officer at the earliest possible stage.

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.