Anti-Slavery Child Labour and Human Trafficking Policy

1. Policy Statement

1.1 It is the policy of the Company to have a zero-tolerance approach to modern slavery, child labour and human trafficking in our operations and supply chains.

1.2 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 which seek to ensure modern slavery or child labour is not taking place in our own business or in any of our supply chains.

1.3 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery or child labour in our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all our suppliers and other business partners, and we prohibit 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.

1.4 This policy applies to all persons working for us, or on our behalf in any capacity, including employees at all levels, directors, agency workers, agents, contractors, sub-contractors, external consultants, third party representatives and business partners (associated persons).

2. Responsibility for the Policy

2.1 The Board of Directors 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 Board of Directors takes modern slavery and child labour into account when making all decisions, but in particular decisions on purchasing, and places continuous emphasis on the importance of preventing and mitigating the risks of modern slavery and child labour in the Company’s supply chains.

2.2 The Company Secretary has primary and day to day responsibility for implementing this policy, monitoring its use and effectiveness and auditing internal controls and procedures to ensure that they are effective in countering modern slavery and child labour.

2.3 The Management of the Company at all levels are responsible for ensuring those reporting to them understand and comply with this policy.

3. Compliance with the Policy

3.1 All employees must read, understand and comply with this policy.

3.2 The prevention, detection and reporting of modern slavery or child labour in any part of our business or supply chains is the responsibility of all those working for us or under our control and any breach, or suspected breach, must be reported immediately to the Company Secretary.

3.3 If you suspect that a conflict with this policy has occurred, or may occur, you must notify the Company Secretary as soon as possible.

3.4 You are encouraged to raise concerns about any issues or suspicions of modern slavery or child labour in any part of our business or supply chains.

3.5 The Board of Directors aims 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.

4. Communication and Awareness of this Policy

4.1 The Company’s zero-tolerance approach to modern slavery or child labour in its business and supply chains must be communicated to all suppliers and associated persons at the outset of a business relationship and reinforced as appropriate thereafter.

5. Breaches of this Policy

5.1 Any employee who breaches this policy will face disciplinary action for gross misconduct which could result in dismissal.

5.2 The Company may terminate its relationship with other individuals and organisations working on its behalf if they breach this policy.

Policy approved 16th March 2021

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