APPROVED BY: F Cross DATE 02.12.2021

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
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, sub-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.
Management at all levels are responsible for ensuring those reporting to them
understand and comply with this policy.
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.

APPROVED BY: F Cross DATE 02.12.2021
Reason for Change: CCF:
Policy Issue No. 1 Page 2 of 3
Cloud\administration\iso\policies\Anti-Slavery Policy Statement
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
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.
You are encouraged to raise concerns about any issue or suspicion of
modern slavery in any parts of our business or supply chains of any supplier tier
at the earliest possible stage. If you believe or suspect a breach of this policy
has occurred or that it may occur, you must notify your line manager or
company Director as soon as possible.
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.
Detrimental treatment includes dismissal, disciplinary action, threats or other
unfavourable treatment connected with raising a concern.
If you believe that you have suffered any such treatment, you should inform
your line manager immediately. If the matter is not remedied, and you are
an employee, you should raise it formally using our Grievance Procedure,
which can be found in the current employee handbook.
This Modern (Anti) Slavery Policy and Statement is intended for businesses in
the United Kingdom.
Communication & awareness of this policy
This Policy forms part of the Company Induction Training process for all
individuals who are employed by the Company. Updates will be provided
using established methods of communication between the Company and
employees. 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

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