Modern Slavery & Human Trafficking Statement.

Objective

Modern slavery relates to the exploitation of children and adults in slavery, servitude, or forced compulsory labour. Human trafficking is the recruitment, movement, harbouring or receiving of children and adults through coercion, deception or force for the purposes of exploitation.

Modern slavery and human trafficking is primarily motivated by profit, with consumer demand for the services provided by victims creating opportunities for exploitation.

Our firm is committed to driving out acts of modern-day slavery and human trafficking within its business and from within its supply chain, including sub-contractors and staff. Within our organisation, and as part of our commitments, we want to:

• act transparently and disclose information about any modern slavery risks which we have identified and what actions we have taken in response to them;
• target our actions where they can have the most impact by prioritising risks;
• make year-on-year progress to address those risks and improve outcomes for workers in our business and supply chains.

Scope

Suppliers, contractors, sub-contractors and staff.

Statement

Our firm acknowledges responsibility to the Modern Slavery Act 2015 and will ensure transparency within our organisation and with suppliers of goods and services to the organisation. These, as well as the suppliers of services, make up the supply chain within our firm.

Our firm currently only sources its products and goods from within the UK and EU.

As part of our organisation's due diligence processes into slavery and human trafficking, the supplier approval process will incorporate a review of the controls undertaken by the supplier. Imported goods from outside the UK and EU are potentially more at risk for slavery and human trafficking issues. The level of management control required for these sources will be continually monitored by the director of our firm.

We will encourage suppliers and contractors, and exercise influence, to adopt responsible business policies and practices including working towards eliminating modern slavery and human trafficking in supply chains.

We will communicate to our business partners and suppliers our commitment against modern slavery and human-trafficking-related practices (although we are not expected to guarantee that all our supply chains are "slavery free").

Our company will not support or deal with any business knowingly involved in slavery or human trafficking. The company director(s) and senior management shall take responsibility for implementing this policy statement and its objectives and shall provide adequate resources (training, etc.) and investment to ensure that slavery and human trafficking is not taking place within the organisation and within its supply chain.

A full copy of this policy and a copy of the Modern Slavery Act 2015 will be accessible to all employees electronically and can be obtained from the HR department upon request.

This policy statement will be reviewed annually. We will publish our modern slavery statement on our UK website, placing the link in a prominent place, and we will provide a copy of the statement in writing to anyone who requests one within 30 days of receiving the request.

This policy and statement take into account, and support, the policies, procedures and requirements documented in our Quality Management System. The implementation and operation of this management system underlines our commitment to this policy. Formal procedures concerning slavery and human trafficking have been established, including disciplinary procedures where they are breached. This policy is communicated to all levels of the company and is regularly reviewed by the director(s) to ensure its continuing suitability and relevance to the company's activities.

The aims of this policy and statement are communicated to new staff upon joining and at annual staff reviews.

Who needs to publish a statement?

A commercial organisation is required to publish an annual statement if it:

• is a "body corporate" or a partnership, wherever incorporated or formed;
• carries on a business, or part of a business, in the UK;
• supplies goods or services; and
• has an annual turnover of £36 million or more.

Organisations are responsible for determining whether the legislation applies to them.

Turnover

"Total turnover" means the turnover of an organisation and any of its subsidiary undertakings (including those operating wholly outside the UK).

"Turnover" means the amount received from the provision of goods and services falling within the ordinary activities of the organisation or its subsidiary undertakings, after the deduction of:

• trade discounts;
• value added tax;
• any other taxes.

We confirm that we are a relevant commercial organisation as defined by Section 54 of the Modern Slavery Act 2015 and that we are compliant with annual reporting requirements contained in Section 54 of the Modern Slavery Act 2015.

The Modern Slavery Act 2015 imposes reporting obligations on all commercial organisations supplying goods or services which carry on their business, or part of their business, in the UK and which have a total turnover exceeding £36 million in any financial year.

Our turnover does not exceed £36 million in any financial year.

Annual review

This document will be reviewed at least on an annual basis.