ANTI-SLAVERY & HUMAN TRAFFICKING POLICY
1.0 Purpose
1.1 Connexion Technologies Ltd is committed to preventing slavery and human trafficking in its business operations and supply chains. This policy outlines our zero-tolerance approach and the systems we have put in place to prevent modern slavery.
1.2 This policy has been developed in accordance with The Modern Slavery Act 2015.
2.0 This policy applies to:
2.1 All persons working for Connexion Technologies Ltd or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, agents, contractors, consultants, and suppliers.
2.2 Our global supply chain, including all subcontractors, business partners, and agents.
3.0 Definitions
3.1 Modern Slavery: Encompasses slavery, servitude, forced and compulsory labour, bonded labour, child labour, and human trafficking.
3.2 Human Trafficking: Where a person arranges or facilitates the travel of another person with a view to that person being exploited.
Modern slavery is a crime and a violation of fundamental human rights.
4.0 Our Commitment
4.1 Connexion Technologies Ltd has a zero-tolerance approach to modern slavery. We are committed to:
- Acting ethically and with integrity in all business dealings.
- Implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or supply chains.
- Ensuring transparency in our approach to tackling modern slavery consistent with our disclosure obligations under Section 54 of the Modern Slavery Act 2015 (where applicable).
5.0 Responsibilities
5.1 We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains and have the following expectations:
- Senior Leadership: Responsible for implementing this policy, monitoring its use and effectiveness, and dealing with any queries about it.
- All Employees and Workers: Responsible for understanding, complying with, and reporting any suspected breaches of this policy.
- Suppliers and Contractors: Expected to comply with this policy and ensure their supply chains do not involve modern slavery or human trafficking.
6.0 Due Diligence and Risk Assessment
6.1 We conduct due diligence activities to identify and mitigate risks of modern slavery. Our processes include:
- Including contractual provisions prohibiting modern slavery.
- Conducting audits of high-risk suppliers where necessary.
- Audit recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance.
6.2 As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out in person audits of suppliers for their compliance.
7.0 Training
7.1 We provide training to staff, particularly those involved in procurement, supply chain management, and recruitment, to help them:
- Recognise signs of modern slavery and human trafficking.
- Understand reporting responsibilities.
8.0 Reporting Concerns
8.1 All employees, contractors, and suppliers are encouraged to report concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at the earliest possible stage. Reports can be made:
- To a line manager or HR representative.
- Confidentially through the company's whistleblowing procedure.
8.2 All reports will be treated seriously, investigated, and appropriate action will be taken
9.0 Breaches of Policy
9.1 Any breach of this policy by an employee will result in disciplinary action, which could include dismissal for gross misconduct. Suppliers or contractors who breach this policy may face termination of contract or business relationship.
10.0 Review of Policy
This policy will be reviewed annually or sooner if there are changes in relevant legislation or our business operations.
Approved by:
Sophie Hallett-Jones
On behalf of The Connexion Technologies Group
Date: 1 August 2025