Organisation
This statement applies to the Company. The information included in the statement refers to the financial year of 01 January to 31 December.
The labour supplied to the Company in pursuance of its operation is carried out in United Kingdom.

Definitions
The Company considers that modern slavery encompasses:

• Human trafficking
• Forced work, through mental or physical threat
• Being owned or controlled by an employer through mental or physical abuse of the threat of abuse
• Being dehumanised, treated as a commodity or being bought or sold as property
• Being physically constrained or to have restriction placed on freedom of movement.

Commitment
The Company acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Company understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Company does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Company in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Company strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in England and Wales.

Potential exposure
In general, the Company considers its exposure to slavery/human trafficking to be relatively limited. It has taken steps to ensure that such practices do not take place in its business nor the business of any Company that supplies goods and/or services to it.

Steps
The Company carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its Company or supply chains, including conducting a review of the controls of its suppliers.

The Company has not, to its knowledge, conducted any business with another Company which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Company follows these steps to ensure that modern slavery is not taking place:

• The zero-tolerance approach to modern slavery and human trafficking in our Company and our supply chains.
• The prevention, detection and reporting of modern slavery and human trafficking in any part of our Company or supply chain, which 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 engage 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 ensure these are kept under review. We assess whether the circumstances require the use 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 benefits of writing to suppliers requiring them to comply with our policies which sets out the minimum standards required to combat modern slavery and trafficking.

The Company has not, to its knowledge, conducted any business with another Company which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Company follows these steps to ensure that modern slavery is not taking place:

• Consistent with our risk-based approach we may require:
• Employment and recruitment agencies and other third parties supplying workers to our Company to confirm their compliance with our policies.
• Suppliers engaging workers through a third party to obtain their agreement to comply with our policies.
• As part of due diligence and ongoing risk assessment, we will consider whether we are required to carry out audits of suppliers, to ensure their compliance with our policies.
• If during this due diligence we discover that other individuals or Company who are working on our behalf have breached this policy, the appropriate action will be taken. This could be remediating the breach or discussing whether the impact is high enough to warrant the termination of the relationship.