Anti-Slavery Policy

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

We have a zero-tolerance approach to modern slavery, and 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 business or in any of our supply chains.

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

2. Responsibility

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. All staff are required to:

• Avoid any activity that might lead to, or suggest, a breach of this policy
• Report any concerns about modern slavery in any parts of our business or supply chains at the earliest possible stage
• Adhere to all fair employment practices and comply with relevant employment laws
• Report any suspected breach of this policy to a manager or director

3. Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have adopted the following due diligence procedures:

• Conducting risk assessments to identify potential risks in our supply chains
• Evaluating and addressing modern slavery risks when entering new supplier relationships
• Including modern slavery provisions in supplier contracts where appropriate
• Taking steps to investigate and address any issues that may arise

4. Indicators of Modern Slavery

Staff should be aware of the following potential indicators of modern slavery:

• Workers who appear to be under the control of others, are unwilling to interact, or appear frightened
• Workers who show signs of physical or psychological abuse, appear malnourished, or unkempt
• Workers who are living in cramped, dirty, or overcrowded accommodation
• Workers who have no access to their earnings, do not have employment contracts, or are paid less than minimum wage
• Workers who have no access to their identity documents (passport, ID cards)
• Workers who are transported to and from work

5. Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant staff. This training helps employees identify the signs of modern slavery and understand how to report concerns.

All directors and senior managers have been briefed on the Modern Slavery Act 2015 and its requirements. We will continue to ensure that all staff receive appropriate training on this policy.

6. Supplier Adherence

We expect the same high standards from all of our contractors, suppliers, and other business partners. As part of our contracting processes, we 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 that our suppliers will hold their own suppliers to the same high standards. Any serious violations of this policy by a supplier may lead to the termination of our business relationship with that supplier.

7. Breach of Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

8. Reporting Concerns

We encourage all employees, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.

You can report concerns by contacting:

Alternatively, you can report concerns to the Modern Slavery Helpline on 08000 121 700, or via their website at www.modernslaveryhelpline.org

9. Review

The directors of Infinity Pulse will review and update this policy as required. All staff are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing. Staff are invited to comment on this policy and suggest ways in which it might be improved.