Policy & Brief

Slavery and human trafficking continue to be significant global issues. We all have a responsibility to be vigilant about potential risks within our business operations and throughout our supply chain. Staff are expected to report any concerns, and management is committed to addressing them promptly.

We are dedicated to ensuring that slavery and human trafficking are not present in our supply chains or any part of our business. This Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships. We implement and enforce effective systems and controls to prevent slavery and human trafficking in our supply chains.

Initiatives to Identify and Mitigate Risk:

• Building Long-Term Supplier Relationships: We aim to establish enduring relationships with local suppliers, clearly communicating our expectations regarding business conduct.

• Engaging with UK Entities: For national or international supply chains, we prefer to engage with UK-based companies or branches. We expect these entities to have robust anti-slavery and human trafficking policies and processes.

• Due Diligence in the Supply Chain: We require each entity in the supply chain to conduct at least 'one-up' due diligence on the next link in the chain.

• Supplier Due Diligence Procedure: As part of our supplier due diligence, we request copies of policies and signed confirmations from suppliers affirming their adherence to applicable legislation.

Recognizing that it is not practical for us to have direct relationships with every link in the supply chain, we have established systems to encourage the reporting of concerns and protect whistleblowers. We maintain a zero-tolerance policy toward slavery and human trafficking and expect all those in our supply chain and contractors to comply with our values.

Responsibilities:

Company Directors are responsible for compliance within their respective departments and for managing supplier relationships.

Training and Awareness:

To ensure a high level of understanding of the risks associated with modern slavery and human trafficking in our supply chains and business, we provide training to relevant staff members. All Directors have been briefed on this subject.

Key Performance Indicators (KPIs):

We measure the effectiveness of our efforts to prevent slavery and human trafficking through the following KPIs:

• Completion of Premises Audits: Conducted by Safety, Health, and Environmental Managers and consultants.

• Right to Work Eligibility Checks: Implemented during our recruitment process.

• Communication and Contact Levels: Assessing the extent of communication and personal contact with the next link in the supply chain and their understanding of, and compliance with, our expectations.

By adhering to these policies and procedures, we strive to maintain ethical standards and ensure that slavery and human trafficking are not present in any part of our business or supply chains.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes C&C's slavery and human trafficking statement.