Anti-Slavery and Human Trafficking Policy

Modern slavery is a criminal offence under the Modern Slavery Act 2015 (the “Act”). Modern

slavery can occur in various forms, including servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. This document sets out the policy of J.P. Wild

Limited (the “Company”) with the aim of the prevention of opportunities for modern slavery to

occur within its businesses or supply chain. This policy’s use of the term “modern slavery” has

the meaning given in the Act.

The Company has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own businesses or those of our suppliers.

We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery. We expect the same high standards from all of our subcontractors, suppliers and other business partners. Our contracting processes include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect our suppliers to hold their own suppliers to the same high standards.

All employees have an obligation to familiarise themselves with this policy and our procedures to help in the identification and prevention of modern slavery and to conduct business in a manner such that the opportunity for and incidence of modern slavery is prevented.

Adherence to this policy forms part of all employee’s obligations under their contract of employment.

Steps the Company has taken to ensure compliance with the Act include:

• Operating a standardised payment system and proof of payment that includes clear documentation of the hour’s employees have worked with details of any legal deductions made for tax, national insurance, student loans etc.
• Ensuring any deductions made do not result in the amount any employee receives is below the minimum wage.
• Paying employees at regular intervals, on set dates and transferring money into a bank account in the employee’s own name.
• Ensuring contracts of employment offered to employees state the basis of their remuneration including details of wage rates, salary payments, hours of work, wage deductions, overtime arrangements, relevant policies including conditions for terminating employment.
• Providing training that may be required to assist staff identify instance of noncompliance with the Act.
• The introduction of contractual provisions for our subcontractors and suppliers to confirm their compliance with the Act.

Ultimate responsibility for the prevention of modern slavery rests with the board of directors. The board of directors has overall responsibility for ensuring this policy, and its implementation; comply with our legal and ethical obligations.

Department heads are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate training on it and the issue of modern slavery.

The Company’s Whistleblowing Procedure is intended to provide guidance on how concerns can be communicated to the Company.

Concerns about suspected modern slavery associated with the Company or our suppliers may be reported by employees in this manner.

The Whistleblowing Procedure applies to employees and may be found in this Handbook section 14.

In summary, an employee should initially raise his or her concern about the above practices or actions with a Company Director. The nature of the complaint will determine the Company’s next course of action.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.

Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

The Company will accept and take seriously concerns communicated anonymously. However, retention of anonymity does render investigations and validation more difficult and can make the process less effective. Individuals are therefore encouraged to put their names to allegations.

Any claims or allegations made which are found to be malicious or vexatious will result in disciplinary action being taken against the individual.

Our zero-tolerance approach to modern slavery will be communicated to all suppliers, and subcontractors at the outset of our business relationship with them and will be reinforced as appropriate thereafter.

Signed on behalf of JP Wild Ltd
JP Doherty Managing Director