Schedule 5 ANTI-SLAVERY AND HUMAN TRAFFICKING 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.

1.3 This policy applies to Staff, and all 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.

1.4 This policy does not form part of any Staff member’s contract of employment or engagement. and we may amend it at any time.

2 RESPONSIBILITY FOR THE POLICY

2.1 The board of directors has overall responsibility for ensuring this policy complies with our legal and

ethical obligations, and that all those under our control comply with it.

2.2 The compliance manager 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.

2.3 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.

2.4 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 compliance manager.

3 ACTIONS WE TAKE TO HELP IDENTIFY AND ERADICATE MODERN SLAVERY MAY INCLUDE: 3.1 Conduct

robust due diligence when establishing relationships with agencies: (a) Establish in particular that the

VAT number being used is legitimate.

(b) Ensure that the organization has never been convicted of offences relating to modern

slavery.

3.2 Conduct regular checks into agencies which we have ongoing relationships with to ensure that they are

continuing to comply with relevant legislation and preventative measures to combat modern slavery.

3.3 Ensure that each individual on the payroll is being paid into a separate bank account and that the name

on the account matches the name of the individual.

3.4 Provide training for staff in identifying the signs of modern slavery and human trafficking, and what

steps should be taken if exploitation is suspected.