Systems and processes to identify, manage, and respond to risks of modern slavery within our operations and supply chains

Our modern slavery policy outlines our commitment to identifying and preventing modern slavery within our operations and supply chains.

This policy will be:

• Posted to our website;

• Communicated to all relevant stakeholders; and

• Reviewed at least annually to ensure it remains effective and relevant.

Risk Assessment and due diligence
We will conduct a thorough risk assessment of our operations and supply chains to identify potential areas of modern slavery risk. This will include an analysis of our suppliers, contractors, and other business partners to determine their modern slavery risk profiles.

We will contact every current and potential supplier we identify as medium to high risk with the following;

[Date]

[Supplier's Name and Address]

Dear [Supplier's Name],

As part of our commitment to ensuring ethical and responsible business practices within our supply chain, we are conducting a due diligence assessment of our suppliers and business partners.

Our aim is to identify and address any potential risks of modern slavery and human trafficking in our supply chain.

To help us better understand your company's operations and potential risks, we kindly request your cooperation in completing the following questionnaire:

• Does your company have a policy in place that prohibits the use of forced labour, modern slavery, or human trafficking?

• Does your company provide any training to employees or suppliers on preventing and identifying modern slavery and human trafficking?

• Does your company require any third-party suppliers or contractors to comply with policies or practices related to preventing modern slavery and human trafficking?

• Does your company have any procedures in place for workers to report any concerns or complaints related to working conditions or potential instances of modern slavery or human trafficking?

• Has your company ever been found to be in violation of any laws or regulations related to modern slavery or human trafficking?

• Is there anything else you would like to share about your company's policies or practices related to preventing modern slavery and human trafficking?

We appreciate your cooperation in completing this questionnaire and helping us to ensure responsible and ethical practices in our supply chain.

Please be assured that any information provided will be treated confidentially and used solely for the purpose of assessing and addressing potential modern slavery risks.

Thank you for your commitment to responsible business practices.


Supplier Engagement
We will engage with our suppliers and other business partners to encourage them to adopt and implement modern slavery policies and procedures. This engagement will include regular communication and training to ensure they are aware of their responsibilities, and the risks of modern slavery.

Supplier code of conduct
We will ask all our suppliers to adhere to the following code of conduct as part of their supply contract with us. We will keep that record on file. We will also ask them to confirm that they have sought similar commitments from their tier 2 suppliers:

Supplier Code of Conduct: Modern Slavery Prevention

As a supplier to Exchange Supplies, we confirm we are committed to ensuring that our operations and supply chains are free from any form of modern slavery, human trafficking, forced labour, or child labour.

We recognise the importance of this issue and will comply with all applicable laws and regulations related to modern slavery prevention. This code of conduct sets out the minimum standards that we agree to meet.

Prohibition of Modern Slavery:
We will not engage in any form of modern slavery, human trafficking, forced labour, or child labour. This includes, but is not limited to, debt bondage, involuntary servitude, and forced marriage.

Fair Employment Practices
We will provide our employees with fair wages and benefits, working hours that comply with applicable laws, and safe and healthy working conditions. We will also ensure that our employees have the right to join a trade union and to engage in collective bargaining.

Prevention of Forced Labour
We will not use any form of forced labour, including but not limited to, bonded labour, prison labour, or any other form of compulsory labour.

Prevention of Child Labour
We will not employ children under the minimum age for employment established by local laws and regulations, or under the age of 15, whichever is higher. We will also comply with all applicable laws and regulations relating to the employment of children and young people.

Identification and Remediation of Modern Slavery
We will conduct due diligence to identify any potential risk of modern slavery within our own operations and our supply chain. If modern slavery is identified, we will take appropriate remedial action, including but not limited to, providing support to affected workers and implementing corrective measures to prevent the recurrence of such incidents.

Compliance with Laws and Regulations
We will comply with all applicable laws and regulations related to modern slavery prevention, including those related to employment, health and safety, and the environment.

Reporting and Monitoring
We will regularly report to our customers on our compliance with this code of conduct and any actions taken to prevent modern slavery. Our customers reserve the right to audit our compliance with this code of conduct, and to terminate our relationship if we do not comply.

Conclusion
We take our responsibility to prevent modern slavery in our operations and supply chain seriously. We understand the importance of this issue, and agree to comply with all applicable laws and regulations related to modern slavery prevention. We will work collaboratively to ensure that our supply chain is free from any form of modern slavery, human trafficking, forced labour, or child labour.

We will inform Exchange Supplies immediately if we become aware of any instances of modern slavery in our company, or tier 2 supply chain.

Signed



Date.

Failure to sign will result in further investigation, and may result in termination of the supply relationship.


Employee Training
Using our online training portal, we will train all employees on the risks of modern slavery and how to identify and report potential incidents.

This training will be provided on induction, regularly and reinforced through ongoing communication and awareness-raising activities.

Whistle blowing
We have a confidential and independent whistle blowing mechanism to allow employees and other stakeholders to report incidents of modern slavery. We will ensure that this mechanism is widely publicised and accessible to all stakeholders.

Incident Response
We will establish a clear and effective incident response procedure to ensure that any incidents of modern slavery are promptly identified and addressed. This will include appropriate measures to protect victims and prevent further harm.

Communication and Transparency
We will be transparent about our efforts to identify and prevent modern slavery within our operations and supply chains. We will communicate with stakeholders, including customers, investors, and civil society organisations, about our progress and any challenges we may face.

By implementing a due diligence system and suitable processes to identify, manage, and respond to risks of modern slavery within our operations and supply chains, we can help to ensure that we are not contributing to, or benefiting from, this heinous practice.

 
Systems and processes to identify, manage, and respond to risks of modern slavery annual audit checklist

We will annually audit these policies and conduct the following audit checks to ensure that:

• The policies are visible on our website, and have been promoted via at least one social media channel, and regularly communicated by our supplier and customer management teams;

• All staff have read and understood the policies on our online elearning system;

• Relevant suppliers have had their modern slavery risk profile checked, and have returned their questionnaire, had the responses reviewed, signed the supplier code of conduct, and where action is needed there is a plan that is being executed; and

• Any issues that have been dealt with via our whistle blowing, incident response, and grievance procedures have had outcomes in harmony with the policy.