Modern Slavery.

This statement is made under section 54(1) of the Modern Slavery Act 2015. It constitutes our Group’s slavery and human trafficking statement for the financial year ending 31st March 2022.It sets out the steps that we have taken, to identify and reduce the risk of modern slavery occurring within our supply chain and business operations. Modern Slavery is a term used to encapsulate two offences in the modern Slavery Act 2015.

1. Slavery, servitude and forced or compulsory labour.
2. Human trafficking. We have a responsibility to ensure that workers are not being exploited, that they are safe and that relevant employment, health and safety, human rights laws and international standards are adhered to, including freedom of movement and communications. We are committed to improving our practices to combat slavery and human trafficking.

Commitments

We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

We have a zero-tolerance approach to modern slavery in our organisation and our supply chains. The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.

We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.

We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties.

Using our risked-based approach we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking. Consistent with our risk-based approach we may require the following to confirm they comply with the Modern Slavery Act 2015:

Employment and recruitment agencies and other third parties supplying workers to our organization. Suppliers engaging workers through a third party. If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.

This policy will be reviewed annually or earlier if significant changes occur, to ensure its continuing suitability, adequacy and effectiveness.