Modern Slavery and Human Trafficking Policy

The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and operates a zero tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or in any of our supply chains.

Responsibility

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

• Policies: Reviewing and putting in place the relevant polices in relation to slavery and human trafficking is the responsibility of the Directors within each part of the business.
• Investigations/due diligence: The Directors are responsible for compliance in their respective business units and for their supplier relationships.
• Training: We will provide training to relevant members of staff at induction and throughout employment where relevant to ensure that they understand the risks of modern slavery infiltrating our business or supply chains. Effective operation of our policies and procedures are aimed at mitigating this risk.

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.

• 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.

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:

• Monitoring 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
• We have in place policies and systems to encourage the reporting of concerns and the protection of whistle blowers.
• Engage with our suppliers both to convey to the Anti-slavery and human trafficking policy and to gain an understanding of the measures taken by them to ensure modern slavery is not occurring in their businesses.
• Where possible we build long standing relationships with suppliers and make clear our expectations of business behaviour.
• 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.

Communication and awareness of this policy

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

The policy will be communicated to all employees across the business and training provided where appropriate. Employees will be expected to familiarise themselves with the statement.

The Company statement will be communicated on our company website and intranet page.