MODERN SLAVERY & HUMAN TRAFFICKING PREVENTION POLICY STATEMENT

Policy Statement

Clearwater People Solutions Ltd is committed to preventing modern slavery and human trafficking in all aspects of its operations and supply chains. We uphold the principles of the Modern Slavery Act 2015 and ensure transparency in our business practises. This policy outlines our commitment to ethical business conduct and the steps we take to mitigate risks related to modern slavery.

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Legal and Regulatory Compliance

We comply with all applicable laws and regulations, including:

• The Modern Slavery Act 2015

• The UK Human Rights Act 1998

• Other relevant UK employment and anti-trafficking laws.

Our Commitment

• Conduct due diligence to identify and mitigate risks of modern slavery in our supply chains.

• Implement policies and procedures to prevent forced labour and exploitation.

• Provide training for employees on recognizing and reporting on modern slavery concerns.

• Maintain open communication channels for whistleblowing and reporting unethical practises.

• Engage with suppliers and business partners to promote ethical sourcing and fair working conditions.

Supplier Code of Conduct

We require all our suppliers to comply with our Supplier Code of Conduct, which includes:

• Prohibiting the use of forced or child labour.

• Ensuring fair wages and safe working conditions.

• Upholding workers’ rights to freedom of association and collective bargaining.

Reporting and Whistleblowing

Employees, suppliers, and stakeholders are encouraged to report any concerns regarding modern slavery through our confidential whistleblowing mechanism. Reports will be investigated promptly, and appropriate action will be taken.

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Monitoring and Reviewing

This policy is reviewed annually to ensure continued compliance with legislation and best practises. Performance indicators, supplier audits, and feedback mechanisms are use to assess the effectiveness of our approach.

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Date Reviewed: February 2025

Next Review Date: February 2026

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