Slavery and Human Trafficking Statement

What this policy covers

Slavery and Human Trafficking is a hidden blight on our society. We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain. This statement covers all companies in the Nicholls & Clarke Group.

Our Commitment

Our Company is committed to ensuring that there is no slavery or human trafficking in our supply chains or in any part of our business. We have zero tolerance on this. We are committed to acting ethically and with integrity in all our business relationships and taking reasonable steps to ensure slavery and human trafficking are not taking place in any business or organisation that has any sort of a business relationship with our Company. Nicholls & Clarke complies with the employment laws of every country in which we operate and expects those with whom it does business to do the same. Nicholls & Clarke also complies with national and international law governing supply chain management and expects those with whom it does business to comply with our values and all applicable law.

Due diligence processes for slavery and human trafficking

As part of our initiative to identify and mitigate risk the Company has in place training to help staff identify problems and systems to encourage the reporting of concerns and the protection of whistleblowers.
Nicholls & Clarke also conducts factory visits to many of its’ major suppliers. Any supplier that we feel does not meet our standards will not receive further orders from us. We have conducted research to assess the risk to us.

Our assessments are:

1)     Where our supply chain providers are based in the UK, we expect these entities to have suitable anti-slavery and human trafficking policies and processes.
2)     Where our supply chain providers are based in countries where the risk of modern slavery is currently low such as countries in the EU, we expect these entities to comply fully with the employment legislation of the country where they are based.
3)     Where our supply chain providers are in countries where the risk of modern slavery is perceived to be higher, we will only place significant orders after we have received written confirmation of adherence to compliance with our standards. This will be reviewed annually.
4)     In one of our businesses we employ sub-contractors. In some instances the sub-contractors employ workers from outside the UK. We are conscious that is a high risk area and we conduct checks to ensure that the sub-contractor is treating their workers fairly. We prefer to directly contract with individuals rather than through an agency.

Training

The management team who are responsible for compliance in their supplier relationships have been provided with training to recognise signs of modern slavery and human trafficking. All employees receive an induction into the business where our policies, procedures and expectations are outlined.

Our effectiveness in combating slavery and human trafficking

The Company uses the following key performance indicators to measure how effective we have been to ensure that slavery and human

The Company uses the following key performance indicators to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

• Use of labour monitoring, right to work documentation and payroll audits
• We maintain a level of communication and personal contact with the next link in the supply chain to ensure their understanding of, and compliance with, our expectations.
• We regularly review supply chain policies and our working practices.

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes the Company's slavery and human trafficking statement.

Reporting suspicions of slavery

Employees can report any suspicions of slavery either through the Company's Public Interest Disclosure (Whistleblowing) policy or externally to the Modern Slavery Helpline. Details are set out below:

https://www.modernslaveryhelpline.org/

0800 0121 700

This statement was approved by the Directors on 09 August 2021

Name David Forbes

Position Chairman

Date 09 August 2021