MODERN SLAVERY POLICY

1. Policy Statement

Modern slavery is a crime and a gross violation of human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which deprive a person’s liberty by another in order to exploit them for personal or commercial gain.

Maurice Lay distributors Ltd has a zero tolerance approach to modern slavery and we are committed to implementing and enforcing systems to ensure modern slavery is not taking place anywhere in our business.

This policy applies to all persons working for us or on our behalf in any capacity including employees at all levels, directors, agency workers, volunteers, agents, contractors, suppliers or any other people or bodies associated with the business.

2. Responsibility for the Policy

The board of directors has overall responsibility for ensuring this policy complies with our legal obligations and that all those under our control comply with it.

The Anti-Slavery Policy compliance team will work together to ensure that this policy is maintained across all operational areas in accordance with evolving regulatory requirements and to ensure that any breaches or concerns are addressed.

The Financial Director has primary and day responsibility for implementing this policy and monitoring its use and effectiveness, dealing with ant queries and auditing internal systems and procedures to ensure they are effective in countering modern slavery.

3. Communication and Awareness of this Policy

This policy will be communicated to all Maurice Lay Distributors Ltd employees.

Maurice Lay Distributors Ltd employees are required to communicate our zero tolerance approach to modern slavery to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforce our approach as appropriate thereafter.

4. Compliance with the Policy

All persons working for Maurice Lay Distributors Ltd must ensure that they 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. All persons working for Maurice Lay Distributors Ltd are required to avoid any activity that might lead to, or suggest a breach or this policy.

All persons working for Maurice Lay Distributors Ltd must ensure that they read, understand acomply 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. All persons working for Maurice Lay Distributors Ltd are required to avoid any activity that might lead to, or suggest a breach of this policy.

All persons working for Maurice Lay distributors Ltd are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business at the earliest possible stage, by reporting it in accordance with our Whistleblowing Procedure.

5. Due Diligence

In order to give effect to our zero tolerance approach, we have systems in place to ensure that all employees implement our policy. These will be kept under review by the compliance team.

6. Breaches of this Policy

Any breach of this policy will be treated as gross misconduct and may result in dismissal without notice.

We may terminate our relationship with individuals and organisations working on our behalf if they do not comply with this policy.