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Policy on Slavery and Human Trafficking

Stormspell Limited’s Slavery and Human Trafficking Statement is made pursuant to Section 54 of the Modern Slavery Act 2015 ‘Transparency in Supply Chains’.

As part of the organisation’s induction process and throughout workers’ employment with us, we coach all associates to treat others with respect and courtesy as well as ensuring they adhere to all relevant laws, regulations and standards.

The undertaking of the induction process is part of the on-going due diligence process. We focus on ensuring our management team is not only aware of the requirements to be alert to modern slavery but can also address concerns raised by their team or any suppliers. If any worker is found in breach of our policies, we ensure suitable disciplinary action is taken which can include termination.

We allow all individuals who work or provide services to us the right to freely choose employment and, the right to affiliate freely with other individuals. Associates are free to choose whether to join a trade union or not and as a result of our coaching and our Equal Opportunities Policy, we offer an environment which is free from harassment and unlawful discrimination.

We ensure our working practices are in accordance with the Equality Act 2010 and all employment legislation. We do not engage in forced or involuntary labour and have a zero-tolerance approach to the same, meaning we do not tolerate any of our suppliers engaging in such conduct. We require suppliers to certify that they do not participate in any forced or involuntary labour with their workers, subcontractors, agents or associates.

Stormspell Limited works in accordance with the European Court of Human Rights guidance and requirements.

Due Diligence Processes

We use reasonable endeavours to conduct Risk Assessments of all Third Parties ensuring that, through Supplier Questionnaires, we monitor and require a Declaration of their Responsibilities and Compliance to supply goods in accordance and not conflicting with our Policy on Slavery and Human Trafficking.

We aim to ensure that our performance indicators do not put pressure on or influence any modern slavery risk through the negotiation of agreed performance targets with our suppliers.

The global scale of the supply chain increases the risk of not being able to directly monitor the impact of operations of slavery and trafficking outside of our primary supply partners, however, we feel that the collation and commitment of the supplier’s own slavery and human trafficking statements does allow us to understand the impact and risks that may exist within our supply chain and monitor any action plans in place.

National Referral Mechanism

The national referral mechanism is used to identify and refer potential victims of modern slavery and make sure they receive appropriate support.

Transparency In Supply Chains

Certain commercial organisations must publish an annual statement setting out the steps they take to prevent modern slavery in their business and their supply chains. This is a requirement under Section 54 (Transparency in Supply Chains) of the Modern Slavery Act 2015.

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