New Anti SlaveryPolicy

ANTI-SLAVERY POLICY STATEMENT
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.
The Company has 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.
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, in the coming year we will 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.
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.
This policy does not form part of any employee’s contract of employment and we may amend it
at any time.
Responsibility for the policy
The Company has overall responsibility for ensuring this policy complies with our legal and
ethical obligations, and that all those under our control comply with it.
The Company 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.
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.
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 Managing
Director.
Compliance with the policy
You must ensure that you read, understand and comply with this policy.
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.
You must notify your line manager OR a company Director as soon as possible if you believe or
suspect that a conflict with this policy has occurred or may occur in the future.