Modern Slavery / Anti-Slavery & Human Trafficking Policy

Purpose

Modern slavery is a serious crime and a violation of fundamental human rights. It encompasses slavery, servitude, forced or compulsory labour, and human trafficking. All these forms of exploitation involve the deprivation of a person’s liberty for personal or commercial gain.

This policy reaffirms our zero-tolerance approach to modern slavery. We are committed to operating ethically and with integrity in all business dealings and relationships. We will implement and maintain effective systems and controls to prevent modern slavery from occurring within our operations or supply chains.

We are also committed to transparency in line with the Modern Slavery Act 2015 and expect the same high standards from all our suppliers, contractors, and business partners. Our contractual arrangements include explicit prohibitions against the use of forced, compulsory, or trafficked labour—whether involving adults or children—and we expect all our suppliers to adopt similar standards across their own supply chains.

Scope

This policy applies to all individuals working for or on behalf of the organisation in any capacity, including but not limited to:

• Employees at all levels
• Directors and officers
• Agency and temporary staff
• Volunteers and interns
• Contractors and consultants
• Suppliers, partners, and third-party representatives

This policy does not form part of any employment contract and may be amended at any time.

Related Policies and Procedures

This policy interacts with and should be read in conjunction with the following:

• Whistleblowing Policy
• Code of Conduct
• Supplier Code of Practice
• Recruitment and Selection Policy

All documents are accessible via ZEBSOFT.

Responsibilities

The Board of Directors holds ultimate responsibility for this policy and its implementation. Day-to-day responsibility lies with the Legal and Compliance Director, who will:

• Monitor policy effectiveness
• Audit internal controls
• Provide guidance to staff
• Address any concerns or queries

All managers are responsible for ensuring staff within their area of responsibility understand and comply with this policy.

Your Responsibilities

All workers must:

• Read, understand, and comply with this policy
• Report concerns or suspicions of modern slavery, whether in our business or supply chain
• Avoid any activity that might lead to a breach of this policy
• Concerns must be raised immediately with your line manager or the Legal and Compliance Director. Alternatively, you may report concerns through the Whistleblowing Policy.
• If unsure whether particular working practices may constitute modern slavery, you should seek clarification from a Director.

Raising Concerns & Protection

We encourage openness and support anyone who raises genuine concerns in good faith. You will not suffer any detriment for doing so, even if your concern turns out to be unfounded.

• Detrimental treatment includes:
• Dismissal or disciplinary action
• Threats or victimisation
• Any unfavourable treatment connected to raising a concern

If you believe you’ve suffered such treatment, report it to the Compliance Manager. If unresolved and you are an employee, you may escalate it via the Grievance Procedure.

Training & Communication

Training on modern slavery awareness and risk will be provided as needed, particularly for staff involved in procurement, supply chain management, or recruitment.

Our zero-tolerance approach must be communicated to all suppliers and business partners at the outset of the relationship and reinforced periodically.

Policy Breaches

Breaches of this policy by employees will be treated as misconduct or gross misconduct and may result in disciplinary action, including dismissal.

We may terminate contracts with suppliers or partners who are found to be in breach of this policy.

Review and Updates

This policy will be reviewed at least every three years, or earlier if required by changes in legislation or organisational structure.

Policy Metadata

• Effective Date: 01 April 2021
• Next Review Due: 01 April 2026
• Approved by: David Bowman
• Document Version: 1.001
• Document Type: Policy
• Document Classification: Everyone