Modern Slavery Policy

1. Policy Statement

1.1. 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 gain. We have 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.

1.2. 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, we 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, agency workers, seconded workers,
volunteers, interns, agents, 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.

2. Responsibility for the Policy

2.1. The Chief Executive 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 Group
Finance and Operations Director has primary and day-to-day responsibility for
implementing this policy, monitoring its use and effectiveness, dealing with any queries
about it, and auditing internal control systems and procedures to ensure they are effective
in countering modern slavery. Management at all levels are responsible for ensuring those
reporting to them understand and comply with this policy and are given adequate and
regular training on it and the issue of modern slavery in supply chains. 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 Group HR Director.
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3. Compliance With The Policy

3.1. 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
manager, the Finance and Operations Director or the Chief Executive 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 manager or report it in accordance with our Whistleblowing
Policy as soon as possible. If you are unsure about whether a particular act, the treatment
of workers more generally, or their working conditions within any tier of our supply chains
constitutes any of the various forms of modern slavery, raise it with your manager, or the
Finance and Operations Director. We aim to encourage openness and will support anyone
who raises genuine concerns in the public interest 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 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 the Finance and Operations Director immediately. If the matter is not remedied, and
you are an employee, you should raise it formally using our Grievance Procedure.

4. Breaches Of This Policy

4.1. Any employee who breaches this policy will face disciplinary action, which could result in
dismissal for misconduct or gross misconduct. We may terminate our relationship with
other individuals and organisations working on our behalf if they breach this policy.