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Anti-Modern Slavery and Human Trafficking Policy

Introduction

This policy sets out Servelec Group plc’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. Servelec maintains relationships with many different organisations in its supply chain, as well as directly employing large numbers of people. In the light of the general law on employment and human rights and more specifically, the Modern Slavery Act 2015, the Group is absolutely committed to preventing slavery and human trafficking in its corporate activities and to ensuring that its supply chain is free from slavery and human trafficking.

Organisational Structure and Supply Chains

This policy covers all the activities of Servelec and its subsidiaries. It governs all our business dealings and the conduct of all persons or organisations with whom we contract directly or who we appoint to act on our behalf.

We expect all who have, or seek to have, a business relationship with Servelec and/or any member of our Group, to familiarise themselves with our anti-slavery policy and to act at all times in a way which is consistent with our anti-slavery policy.

The Group currently operates in the following countries: United Kingdom, Australia, India, Belgium, UAE, USA, France and Republic of Ireland.

Responsibility

The HR department will liaise with other relevant departments such as the QA & Compliance and the Legal team to ensure that risk analysis and investigations/due diligence in relation to modern slavery and human trafficking is carried out as required.

HR will ensure that employees are given adequate and regular training on the issue of modern slavery so that everyone understands and complies with this policy.

Relevant Policies and Practices

Servelec Group plc operates the following policies and practices that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.

The Group’s policy on whistleblowing encourages all its workers, customers and other business partners to report any concerns related to the direct activities of the organisation or its supply chain. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company’s whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation. Employees who have concerns can refer to the Group’s Whistleblowing Policy which is available on the Company intranet. The nature of the complaint will determine the Group’s next course of action.

We endeavour to carry out our own recruitment activities and/or to only use reputable employment agencies to source labour and we carry out appropriate background checks. Personnel responsible for the recruitment activities in any of the subsidiaries are advised to adhere to this policy by ensuring that strict verification of potential employee’s right to work is carried out before any offer of employment is made.

Servelec Group plc expects its subsidiaries and all supply chain to adhere to recruitment practices that ensure that all terms of employment are voluntary. Where necessary and if required, we may request demonstration of compliance with this policy.

Awareness & Performance Indicators

As well as training employees, the Group will raise awareness of modern slavery issues by emailing the Group’s anti-slavery and human trafficking policy to all employees as well as it being made available on the Group’s intranet. We expect employees to refer to this policy and understand what is required of them in relation to modern slavery.

This policy on modern slavery will be communicated to all suppliers, contractors and business partners at appropriate points during our business relationship with them and reinforced as appropriate thereafter.