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Human Trafficking Statement

Introduction
This statement is made pursuant to section 54(1) of the Modern Slavery Act of 2015 and constitutes the Company’s slavery and human trafficking statement. 
Modern slavery is a crime and a violation of human rights. It takes various forms, including slavery, servitude, compulsory labor and human trafficking for exploitation and can have a significant adverse impact on individuals, families and communities across the world.

Compliance
The Company has a zero-tolerance approach to modern slavery and has adopted a modern slavery policy (” Policy”).  A copy of the Policy can be viewed by clicking here.
The Company’s Chief Executive Officer and the Head of People and Culture have overall responsibility for ensuring compliance with the Company’s legal and ethical obligations and that the Policy is implemented effectively.
As the Company operates from the U.S. there is a low risk of exposure to slavery and human trafficking.
The Company’s key area of risk lies in the relationships with non-U.S. supply chains - suppliers, contractors and business partners. However, the Company also recognize their responsibilities as an employer of staff.

Supply chain
The Company’s zero-tolerance approach to modern slavery is communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
The Company undertakes appropriate due diligence when considering taking on new suppliers, contractors and business partners, and regularly review our existing suppliers, contractors and business partners.
In addition, the Company has conducted due diligence in respect of its current supply chain and has identified partners in India who have been subject to enhanced due diligence and who will be required to confirm in writing their compliance with the Modern Slavery Act of 2015 and include relevant clauses in any contracts or agreements.
The Company sends to all of its suppliers its supplier’s guide which includes anti- slavery language and its general terms and conditions.  All suppliers are required to agree in writing to the supplier’s guide.
A standard supplier contract clause has been drafted requiring compliance with the Modern Slavery Act of 2015 and shall be included in the Company’s general terms and conditions of purchase. In higher risk cases this will include enhanced audit/termination rights to ensure more vigilant monitoring of high risk.
Serious breaches of the supplier guide will result in the termination of the business relationship.

Staff
The Company only uses reputable employment agencies, and we will always verify the practices of any new agency before engaging staff from it.

Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in the Company’s supply chain and business, the Company shall provide training all necessary employees.  Everyone on the leadership team have been briefed on this very important subject.