Modern Slavery Policy _

Policies of “the Company” (Tynefast Holdings Ltd.) apply to all subsidiaries and associated Group organisations. Group will have the meaning attributed to it by section 1261 of the Companies Act 2006 and Group Company will be construed accordingly. Group Company and Group Companies shall mean Group Companies of the Employer.

Introduction

This Statement covers both our own business and our supply chain and is designed to satisfy the requirements of Part 6 of the Modern Slavery Act 2015, by informing our employees, suppliers, other third party partners and clients about its Statement with respect to modern slavery, human trafficking, forced and bonded labour and labour rights violations in its supply chains.

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 which have in common the deprivation of a person's liberty by another to exploit them for personal or commercial gain.

Although, as a business, our turn over is less than the threshold for businesses required to publish a statement under the Act, our Board considers that our customer ‘s spend through its supply agreements warrants a statement on the risks inherent in our supply chains and the steps we are taking to address them, in line with our practices in sustainable and responsible procurement.

We are committed to acquiring goods and services for our customers without causing harm to others. In so doing, we are committed to supporting the UK Government’s Action Plan to implement the UN Guiding Principles on Business and Human Rights.

To Whom This Policy Applies

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, seconded workers, agents, contractors, external consultants, third-party representatives and business partners.

Our categories

Our supply chains mainly fall under 3 categories, which are:

• Labour
• Sub- Contractors
• Suppliers of equipment and services

We are committed to ensure that:

1. Employment is freely chosen;
2. Freedom of association and the right to collective bargaining are respected;
3. Working conditions are safe and hygienic;
4. Child labour shall not be used;
5. Living wages are paid;
6. Working hours are not excessive;
7. No discrimination is practised;
8. Regular employment is provided; and
9. No harsh or inhumane treatment is allowed.

**Risk Assessment and Due Diligence Processes for Slavery and Human Trafficking **

We have in place systems to mitigate the risk of slavery and human trafficking occurring in our supply chains, allowing us to assess, identify, address and monitor risk areas. We assess the risk of slavery or human trafficking occurring in our supply chains and apply enhanced checks where higher-risk areas are identified.

We will carry out risk assessments for new suppliers to consider the likelihood of maltreatment of staff or other unsatisfactory factors. This may mean that we decide not to work with them or seek further information, or assurances, before proceeding. For new suppliers where a higher risk is identified:

If the supplier is required to comply with the Modern Slavery Act 2015, we will review their own published policies on modern slavery.

For other suppliers, we will seek declarations that they meet appropriate requirements and may ask them to give information on their working practices.

We will apply appropriate vetting procedures, based on the level of risk identified, to ensure we are comfortable that any risks involving slavery can be identified and addressed promptly.

**Responsibility for the Policy **

Our Board of Directors have overall responsibility for ensuring compliance with this policy.

Senior management, and project managers, have day-to-day responsibility to ensure compliance with our legal and ethical obligations and are responsible for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and ensuring internal control systems and procedures are effective in countering modern slavery.

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

**Compliance with this Policy **

You must ensure that you read, understand and comply with this policy. 
 
The prevention, detection and reporting of modern slavery in any part of our business or supply chains 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 manager, project manager or Management Team as soon as possible if you believe or suspect 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 any parts of our business or supply chains of any supplier tier or any organisation or third party in receipt of funding managed and administered by us at the earliest possible stage.

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager, project manager or the Management Team.
  
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.

If you believe that you have suffered any such treatment, you should inform your manager, project manager or the Management Tea. immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.