Code of Conduct for Modern Slavery

Slavery is illegal and violates basic human rights. It manifests itself in a variety of ways, including: slavery, servitude, forced labour, forced marriage, debt bondage, and human trafficking.

All of these situations, whether they involve adults or kids, have in common the taking away of someone’s freedom in order to use them for one’s own or another’s benefit.

We are dedicated to conducting ourselves ethically and honestly in all of our business dealings and interactions, as well as to putting in place and upholding efficient processes and controls to make sure modern slavery doesn’t exist anywhere within our own company or any of our supplier chains.

In accordance with our disclosure duties under the UK modern slavery legislation, we are also dedicated to making sure that there is transparency in our own operations and in our strategy for addressing modern slavery throughout our supply chains. From each of our suppliers, contractors, and other business partners, we demand the same high standards. We may specifically prohibit the use of forced, compulsory, or trafficked labour as part of our contracting procedures. We also prohibit the holding of any person, whether an adult or a child, in slavery, servitude, or debt bondage. We expect our suppliers to hold their own suppliers to the same high standards.

Code of Conduct for Responsive Procurement
In our supplier chain, we aggressively encourage environmental, social, and corporate governance (ESG) principles. As part of this procedure, we:

• May add special clauses to supplier contracts that ensure adherence to ESG protections.
• Demand that vendors evaluate and enhance their ESG practises.

We are dedicated to conducting business in an open and accountable manner, and we demand the following of our suppliers:

• Act with integrity, professionalism, and fairness both internally and externally, especially with regard to how their operations influence the community.
• If at all possible, avoid (but always disclose) any conflicts of interest that might affect the commercial agreements between the supplier and us.
• Do not offer gifts to obtain an unfair advantage or preferential treatment in the supplier’s business operations.

We are dedicated to encouraging a health and safety-awareness culture that guarantees workplace risks are eliminated or reduced, and we anticipate the following from our suppliers:

• Comply with all health and safety rules and regulations. We are committed to fostering a culture of health and safety awareness that ensures dangers in the workplace are eliminated or reduced.
• Prevent workplace risks by being proactive (including providing appropriate training to enable workers to perform their jobs safely).

We are dedicated to creating an atmosphere in which employees have equal access to career possibilities, are treated fairly and respectfully, and are not assessed based on unjustified or pointless references to their characteristics, and we demand the following of our suppliers:

• Show respect for all diversity in people and things, including those related to gender, ethnicity, colour, age, disability, sexual orientation, ethnic origin, and religion.
• Actively pursue gender equality (including the participation of both men and women at the same rate) in the workplace or, when relevant, adhere to Workplace Gender Equality Agency reporting requirements.

We are dedicated to upholding the Equal Employment Opportunity (EEO) standards in the workplace and fostering an atmosphere that promotes equality and is free from unjustified harassment, bullying, or discrimination. Suppliers are required to:

• Establish an EEO policy.
• Create a setting where people are treated fairly, equally, with respect, and according to the law.
• Encourage a culture in which harassment and illegal discrimination are not tolerated.
• Offer employees fair compensation and working conditions, including sufficient rest and vacation time and the required minimum wage.
• Provide parental and caregiver leave as mandated by law.

All rules and regulations that apply to them must be followed by our providers.

The people who work for us or on our behalf in any capacity, including all employees at all levels, directors, officers, agency employees, seconded employees, volunteers, interns, agents, contractors, outside consultants, third-party representatives, and business partners, are subject to this Code of Conduct.