Anti-Slavery Policy

‍ANTI-SLAVERY POLICY STATEMENT

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms,such as slavery, servitude, forced and compulsory labour and human trafficking, all of whichhave in common the deprivation of a person’s liberty by another in order to exploit them forpersonal or commercial gain.

Above The Bay Limited has a zero-tolerance approach to modern slavery, and we are committedto acting ethically and with integrity in all our business dealings and relationships and toimplementing and enforcing effective systems and controls to ensure modern slavery is nottaking place anywhere in our own business or in any of our supply chains.

We are also committed to ensuring there is transparency in our own business and in ourapproach to tackling modern slavery throughout our supply chains, consistent with our disclosureobligations under the Modern Slavery Act 2015.

We expect the same high standards from all of our contractors, suppliers and other businesspartners, and as part of our contracting processes, in the coming year we will include specificprohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slaveryor servitude, whether adults or children, and we expect that our suppliers will hold their ownsuppliers to the same high standards.

This policy applies to all persons working for us or on our behalf in any capacity, includingemployees at all levels, directors, officers, agency workers, seconded workers, volunteers,interns, agents, contractors, external consultants, third-party representatives and businesspartners.

This policy does not form part of any employee’s contract of employment and we may amend itat any time.

Responsibility for the policy

Above The Bay Limited has overall responsibility for ensuring this policy complies with our legaland ethical obligations, and that all those under our control comply with it.

Above The Bay Limited has primary and day-to-day responsibility for implementing this policy,monitoring its use and effectiveness, dealing with any queries about it, and auditing internal controlsystems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring those reporting to them understand andcomply with this policy and are given adequate and regular training on it and the issue of modernslavery in supply chains.

You are invited to comment on this policy and suggest ways in which it might be improved.Comments, suggestions and queries are encouraged and should be addressed to the ManagingDirector.

Compliance with the policy

All staff must ensure that they have read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supplychains is the responsibility of all those working for us or under our control.
You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify your line manager OR a company Director as soon as possible if you believe orsuspect that a conflict with this policy has occurred or may occur in the future.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in anyparts of our business or supply chains of any supplier tier at the earliest possible stage.
If you believe or suspect a breach of this policy has occurred or that it may occur, you must notifyyour line manager or company Director OR report it in accordance with our Whistleblowing Policyas soon as possible.

You should note that where appropriate, and with the welfare and safety of local workers as apriority, we will give support and guidance to our suppliers to help them address coercive,abusive and exploitative work practices in their own business and supply chains.

If you are unsure about whether a particular act, the treatment of workers more generally, or theirworking conditions within any tier of our supply chains constitutes any of the various forms ofmodern slavery, raise it with your line manager or company Director.

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

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

If you believe that you have suffered any such treatment, you should inform your line managerimmediately. If the matter is not remedied, and you are an employee, you should raise it formallyusing our Grievance Procedure, which can be found in the current employee handbook.

This Modern (Anti) Slavery Policy and Statement is intended for businesses in all countries,especially the United Kingdom; and was brought to you by Rushax.

Communication & awareness of this policy

Training on this policy, and on the risk our business faces from modern slavery in its supplychains, forms part of the induction process for all individuals who work for us, and updates will beprovided using established methods of communication between the business and you.
Our zero-tolerance approach to modern slavery must be communicated to all suppliers,contractors and business partners at the outset of our business relationship with them andreinforced as appropriate thereafter.

Breaches of this policy

Any employee who breaches this policy will face disciplinary action, which could result indismissal for misconduct or gross misconduct. We may terminate our relationship with otherindividuals and organisations working on our behalf if they breach this policy.

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