Anti-Slavery and Human Trafficking Policy

Introduction

Modern slavery covers slavery, servitude, forced or compulsory labour, bonded and child labour, and human trafficking. Victims are coerced, deceived, or otherwise forced against their free will into providing work or services. Human trafficking involves arranging or facilitating a person's movement with a view to exploiting them. Both are crimes and a violation of fundamental human rights.

The Exclaimer group (we, us or our) prohibits modern slavery and human trafficking in any part of our business or supply chain and is committed to implementing systems and controls designed to ensure neither takes place anywhere within our organisation.

Scope

This Policy applies to everyone working for or on behalf of an Exclaimer group company, including employees at all levels, directors, officers, agency workers, contractors, suppliers and channel partners.

It does not form part of any employee's contract of employment, and we may amend it at any time. We publicise this Policy on our website so that all within its scope are able to read it, and to ensure that they do not engage in, facilitate, or fail to report any activity that might lead to, or suggest, a breach of this Policy.

Non-compliance with this Policy may result in disciplinary action or, for suppliers, contractors and partners, termination of the relationship.

Our commitment

• Zero tolerance. We take a zero-tolerance approach to modern slavery and human trafficking, in our organisation and throughout our supply chain. Preventing, detecting, and reporting modern slavery is the responsibility of everyone working for us or on our behalf.

• Understanding the risk. We work to build a clear understanding of how modern slavery and human trafficking can arise in our sector, who is affected, and where our own risk is greatest.

• Transparency. We publish an annual Modern Slavery Statement in line with Section 54 of the United Kingdom’s Modern Slavery Act 2015, approved by the Board and signed by a director, setting out the steps we have taken to prevent modern slavery and human trafficking in our business and supply chain over the previous 12 months. The statement is reviewed annually and communicated to our employees.

• Third parties. We publish expectations of our supply chain through our Supplier Code of Conduct and Partner Code of Conduct.  We use reasonable endeavours to pass through compliance with these as contractual obligations within our supply chain.

• Supply chain standards. Modern slavery, forced labour, child labour and human trafficking have no place in our operations or supply chain. We use reasonable endeavours to include contractual prohibitions on forced and child labour in supplier agreements. We expect all parties in our supply chain to provide clear employment terms, respect freely chosen employment and freedom of association, comply with local requirements on working hours, and to eliminate all forms of discrimination.

• Labour providers. We require recruitment and employment agencies and other third parties supplying workers to us to comply with the principles set out in our Supplier Code of Conduct. Suppliers that engage workers through a third-party must obtain that third-party's agreement to adhere to such principles.

Our programme

Our programme addresses the following areas:

• Governance and policies: this Policy, our Code of Business Conduct, and our Whistleblowing and Grievance Policies, are each reviewed regularly and re-communicated to all staff.

• Risk assessment: identifying where modern slavery risk is highest across our operations and supply chain, and prioritising action accordingly.

• Due diligence: engaging with suppliers and contractors to address modern slavery risk, and auditing them, on a risk basis, for compliance.

• Remediation: working with suppliers and contractors to remediate non-compliance if/where it is found, and ending the relationship in cases of gross, persistent, or deliberate failure.

• Training: ensuring our people understand and adhere to this Policy, including training for relevant personnel on recognising and reporting indicators of modern slavery.

• Reporting channels: maintaining reporting channels that are accessible, confidential and free from retaliation.

• Monitoring and effectiveness: reviewing the effectiveness of our approach, including against this Policy and our published Modern Slavery Statement.

Raising a Concern

If you believe that modern slavery or human trafficking of any kind: (a) is, or may be, taking place in any part of our business; or (b) may occur in the future in any part of our business; or, (c) have any concern about compliance with this Policy:

• if you are an employee or contractor: notify your manager or report it in accordance with our Grievance Policy, Whistleblowing Policy, or using our Whistleblowing Hotline as soon as possible.

• if you are external to our business: please notify us using our Whistleblowing Hotline as soon as possible.

We encourage openness and will support anyone who raises a genuine concern under this Policy, even if it turns out to be mistaken. No one will suffer detrimental treatment, such as dismissal, disciplinary action, threats, or other unfavourable treatment, as a result of raising a genuine concern.

If you believe you have suffered such detrimental treatment as a result of raising compliance concerns:

• tell your line manager immediately; if the matter is not resolved, employees should raise it formally under our Grievance Policy or using our Whistleblowing Hotline as soon as possible.

• if you are external to our business, please notify us using our Whistleblowing Hotline as soon as possible.

Further questions

If you have questions about this Policy, or about Exclaimer's wider compliance offering, contact your Exclaimer representative or email [email protected].