Anti-Slavery Policy

A.W.Bent Limited (“AWB”) are committed to preventing modern slavery and human trafficking occurring within our organisation and to reducing the risk of occurrence in our supply chain. This policy sets out measures we will take towards this and our expectations of our staff and third parties with whom we work.

What is slavery?

The Modern Slavery Act (MSA) 2015 covers four activities:

Slavery	Exercising powers of ownership over a person.
Servitude	The obligation to provide services is imposed by the use of coercion.
Forced or compulsory labour	Work or services are exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily.
Human trafficking	Arranging or facilitating the travel of another person with a view to their exploitation.

This policy covers all four activities.

Identifying slavery

There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support.

The following key signs could indicate that someone may be a slavery or trafficking victim:

• the person is not in possession of their own passport, identification or travel documents;
• the person is acting as though they are being instructed or coached by someone else;
• they allow others to speak for them when spoken to directly;

• they are dropped off at and collected from work;
• the person is withdrawn or they appear frightened;
• the person does not seem to be able to contact friends or family freely; or
• the person has limited social interaction or contact with people outside their immediate environment.

This list is not exhaustive.

Remember, a person may display a number of the trafficking indicators set out above but they may not necessarily be a victim of slavery or trafficking. Often you will build up a picture of the person’s circumstances which may indicate something is not quite right.

If you have a suspicion, report it.

How is it relevant to us?

Modern slavery is a complex and sophisticated crime and tackling it requires all of us to play a part. At first glance, you may think this whole subject is irrelevant to us, but it’s not.

At a very basic level, of course preventing exploitation and human trafficking, and protecting our workforce and reputation makes good business sense. More importantly, it is simply the right thing to do.

The MSA 2015 recognises the important part businesses can and should play in tackling slavery and encourages them to do more.

We need to pay close attention to the features of our organisation that are particularly vulnerable to these types of practice including:

• our supply chain;
• any outsourced activities, particularly those in higher risk jurisdictions or sectors;
• cleaning and catering suppliers; and
• corporate hospitality.

Responsibilities

AWB, our managers and colleagues have responsibilities to ensure our fellow workers are safeguarded, treated fairly and with dignity.

The Directors of AWB are responsible for our modern slavery risk management strategy and compliance with our legal and ethical obligations.

The Directors of AWB have overall accountability for our organisation’s modern slavery risk management strategy.

Everyone working for us including contractors and consultants must observe this policy and be aware that turning a blind eye is unacceptable, and simply not

an option. Through our strategy, vision and values we communicate our principles, which reflect our approach to modern slavery in our organisation, and in our supply chain.

Organisation responsibilities

We will:

• regularly assess the risk of modern slavery and human trafficking occurring within our organisation and supply chain, and commit to taking steps to reduce those risks;
• ensure we meet applicable legal obligations;
• ensure those leading and implementing our modern slavery strategy and compliance, have appropriate knowledge and expertise, adequate resources and training, and understand their responsibilities;
• develop and communicate internally and to our suppliers, clear policies and procedures setting out our expectations, aimed at preventing slavery and human trafficking and protecting our workforce and reputation;
• implement systems and processes to manage occupational health and safety risks within our organisation and promote the wellbeing of our staff;
• be clear about our recruitment policy and lead by example by making appropriate checks on all
• employees, recruitment agencies, consultants and other relevant contractors to ensure we know who is working for us and by ensuring all those working for us are aware of this policy as part of our onboarding;
• check our supply chains;
• ensure we have open and transparent reporting and grievance processes for all staff , and that there are no barriers to reporting modern slavery concerns or breaches of our policies;
• raise awareness so that our colleagues know what we are doing to promote their welfare;
• make a clear statement setting out the steps we have taken to ensure slavery and human trafficking is not taking place in our organisation or in our supply chains; and
• evaluate our strategy, and measure its effectiveness including the development of our organisational values and ethical behaviours.

Manager responsibilities

Managers will:

• listen and be approachable to colleagues;
• respond appropriately if they are told something that might indicate a colleague or any other person is being exploited;
• remain alert to indicators of slavery;
• raise the awareness of our colleagues, by discussing issues and providing training, so that everyone can spot the signs of trafficking and exploitation and know what to do; and
• use their experience and professional judgement to gauge situations.

Colleagues

We all have responsibilities under this policy. Whatever your role or level of seniority, you must:

• keep your eyes and ears open—if you suspect someone (a colleague or someone in our supply chain) is being controlled or forced by someone else to work or provide services, follow our reporting procedure;
• follow our reporting procedure if a colleague tells
• you something you think might indicate they are or someone else is being exploited or ill-treated;
• tell us if you think there is more we can do to prevent people from being exploited; and
• familiarise yourself with our linked policies and procedures within the Employee Hand-book and Health & Safety Policy.

Our procedures Supply chains

We check and monitor our supply chains to identify, assess and manage modern slavery risks.

We tell the organisations we do business with that we are not prepared to accept any form of exploitation. We actively encourage responsible employment practices in our supply chain to ensure workers are provided with a safe and healthy environment, are aware of their rights, and are able to raise concerns without fear, mirroring our own culture and values.

We seek, where possible, to incorporate anti-slavery obligations in our supplier contracts.

We seek to account for each step of our supply processes—so we know who is providing goods and services to us and we have mechanisms and processes in place to check, including:

• Annual population of supplier questionnaire
• Annual monitoring of Modern Slavery Risk Register

Recruitment

We are committed to ensuring that we and any external recruitment agencies we use have clear and fair recruitment policies and procedures and that no one has to pay directly or indirectly any fees to work for us. As an inclusive employer we ensure that we treat all those working for us, directly or via an agency, fairly.

Using agencies

Our Directors and Managers only use agreed, specified, reputable recruitment agencies with whom we have a written contract in place.

To ensure the potential for slavery and human trafficking is reduced as far as possible, we thoroughly check recruitment agencies before adding them to our list of approved agencies. This includes:

• conducting background checks;
• investigating reputation;
• ensuring the staff provided via an agency have the appropriate paperwork (eg work visas); and
• ensuring the agency provides assurances that the appropriate checks have been made on the person they are supplying.

We keep agents on the list under regular review, at least every 12 months.

General recruitment

We always ensure that prior to starting work, all staff have a written contract of employment describing their work, in an appropriate language, and that they have not had to pay any direct or indirect fees to obtain work.

We always ensure staff are legally able to work in the UK.

We check the names and addresses of our staff (a number of people listing the same address may indicate high shared occupancy, often a factor for those being exploited).

We provide information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to.

If, through our recruitment process, we suspect someone is being exploited, the hiring Manager or Directors will follow our reporting procedures.

Reporting slaveryWe encourage anyone affected by modern slavery or human trafficking, or anyone with concerns that someone within our organisation, supply chain or business associates is affected by modern slavery and human trafficking to speak up. If you raise a concern under this policy in good faith, we will support you, even if you turn out to be mistaken.

Talking to someone about your concerns may stop someone from being exploited or abused.

If you think that someone is in immediate danger, dial 999.

Otherwise, you should discuss your concerns with a Director who will decide a course of action and

provide any further advice, or alternatively follow our whistleblowing policy or our grievance procedures, which you can find in the Employee Handbook.

Not all victims may want to be helped and there may be instances where reporting a suspected trafficking case puts the potential victim at risk, so it is important that in the absence of an immediate danger you discuss your concerns first a Director before taking any further action.

We have procedures in place to investigate any concerns raised and to ensure where appropriate remedial action is taken. Our procedures put victims and workers first. Where an issue concerns part of our supply chain we are committed to working with

those supply chain members to facilitate improvement and education to reduce the risk of future slavery occurrences. Whilst we may consider terminating our relationship, this will not be our starting point.

Training

We will provide specialist training to those staff members who are involved in managing recruitment and our supply chains.

We will provide training for our Directors and Managers on modern slavery risks and relevant issues such as human rights and occupational health and safety.

Monitoring and review

The Directors will review this policy regularly, at least annually, and at additional intervals as may be required regarding:

• our existing and emerging legal obligations;
• emerging modern slavery trends, risks and developments relevant to our organisation including the impact of any changes on our organisation or our approach;
• our Anti-slavery policy and any applicable statement, along with any associated policies, processes and procedures;
• feedback from stakeholder engagement, our audit process and our colleagues;
• the effectiveness of our processes and procedures;
• any recommended changes in our approach;
• any suspected or identified cases of modern slavery; and
• whether or not it is appropriate to consult internally or externally regarding modern slavery risk.

The Directors of AWB will approve any changes to our strategy, policy and procedures, and we will provide information and/or training on any changes we make both internally and through our supply chain, using appropriate methods and channels of communication.

We are committed to continual development and improvement of our approach. If you have any feedback regarding this policy or our approach, please provide this to the Directors