Modern Slavery & Human Trafficking

Policy Statement

Nexo People Limited is committed to preventing modern slavery and human trafficking in all its forms. We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships. We will implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere within our business or in any of our supply chains.

Scope

This policy applies to all individuals working for or on behalf of Nexo People Limited, including employees, directors, officers, agency workers, contractors, consultants, and any third party representing the organisation. It applies to all aspects of our business, including our recruitment services and supply chain operations.

Definitions

Modern slavery

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour, and human trafficking, all of which involve the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

Human trafficking

Human trafficking involves arranging or facilitating the travel of another person with a view to their exploitation. It can include recruitment, transportation, transfer, harbouring, or receipt of persons by means of threat, force, coercion, abduction, fraud, deception, or abuse of power.

Organisational Responsibilities

Nexo People Limited is responsible for:

• Ensuring that modern slavery and human trafficking are not taking place in any part of our business or supply chain
• Conducting due diligence on all new suppliers and regularly reviewing existing suppliers
• Providing training to staff on modern slavery awareness and reporting procedures
• Including anti-slavery and human trafficking clauses in contracts with suppliers and partners
• Maintaining a transparent and open culture where concerns can be raised without fear of retaliation

Worker Responsibilities

All workers are expected to:

• Familiarise themselves with this policy and comply with its provisions
• Report any concerns or suspicions of modern slavery or human trafficking immediately
• Cooperate with any investigation into potential modern slavery or human trafficking

Recognising Modern Slavery

Signs that may indicate modern slavery include but are not limited to:

• Workers appearing to be under the control of others and reluctant to interact
• Workers living in overcrowded or unsuitable accommodation provided by employers
• Workers not having access to their own identity documents
• Workers being transported to and from work and having wages withheld or paid to a third party
• Workers showing signs of physical or psychological abuse, appearing malnourished, unkempt, or withdrawn

Recruitment Practices

As a recruitment agency, we are particularly vigilant about the risk of modern slavery within our operations. We verify the identity and right-to-work status of all candidates, ensure that no worker is charged recruitment fees, conduct thorough checks on all client organisations, monitor working conditions and pay compliance for placed workers, and maintain clear records of all worker placements and associated documentation.

Reporting Concerns

Internal reporting: If you suspect or become aware of any form of modern slavery or human trafficking, you must report it immediately to management or via email at support@nexopeople.com.

External resources for reporting:

• Modern Slavery Helpline: 08000 121 700
• Gangmasters and Labour Abuse Authority (GLAA): www.gla.gov.uk
• Police: Call 999 in an emergency or 101 for non-emergencies

All reports will be treated in the strictest confidence. No worker will suffer any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery or human trafficking is or may be taking place.

Monitoring and Review

This policy will be reviewed annually to ensure its continuing suitability, adequacy, and effectiveness. The effectiveness of the steps we have taken to ensure that modern slavery is not taking place in our business or supply chains will be monitored on an ongoing basis, and we will make improvements where necessary.

Breach of Policy

Any breach of this policy will be taken seriously and may result in:

• Disciplinary action, up to and including dismissal for employees
• Termination of contracts with suppliers, contractors, or other business partners
• Reporting to relevant authorities and law enforcement agencies

Declaration

This statement is made pursuant to the Modern Slavery Act 2015 and constitutes Nexo People Limited's modern slavery and human trafficking statement. It has been approved by the directors of the company and will be reviewed and updated as necessary.