1. Policy Overview

Modern slavery is a crime and a severe violation of human rights. It includes slavery, servitude, forced labour, and human trafficking—all forms of exploitation that deny an individual their freedom. Our organisation is firmly committed to preventing any form of modern slavery within our business operations and supply chains. We enforce strict ethical standards and require all employees, contractors, and partners to uphold these principles.

2. Purpose of the Policy

This policy outlines:

• Our commitment to preventing modern slavery.
• The responsibilities of those working for or on behalf of our organisation.
• Guidance on identifying and reporting potential cases of modern slavery.

It applies to all employees, contractors, suppliers, and third-party representatives.

3. Policy Responsibilities

• Board of Directors: Ensures compliance with legal and ethical obligations.
• Compliance Manager: Oversees policy implementation, monitors its effectiveness, and addresses queries.
• Managers: Provide training and ensure team compliance with this policy.

4. Employee Responsibilities

• Understand and adhere to this policy.
• Be vigilant and report concerns promptly, following the procedures outlined in our Whistleblowing Policy.
• Avoid actions that could lead to or imply involvement in modern slavery.

If unsure about a situation, employees should seek guidance from their manager or the Compliance Manager.

5. Reporting Concerns

Employees are encouraged to raise concerns about any suspected instance of modern slavery within the organization or its supply chains. Reports made in good faith will be treated seriously, and no individual will face retaliation or detrimental treatment for raising a legitimate concern.

6. Training and Communication

• All employees receive training on this policy during onboarding and as needed thereafter.
• Our zero-tolerance approach is communicated to all suppliers, contractors, and business partners at the start of relationships and reinforced periodically.

7. Consequences of Breaching the Policy

• Employees violating this policy may face disciplinary action, up to and including dismissal.
• Contracts with third parties may be terminated if they fail to comply with these principles.