1. Application and Background

This policy applies to Essentia Analytics Limited’s (the “Company”) operations in the United Kingdom and to all persons who work for or on behalf of the Company in respect of such operations.

This policy reflects the Company’s commitment to avoid any form of modern slavery or human trafficking within its operations or its supply chain in accordance with the Modern Slavery Act 2015.

2. What is Modern Slavery?

Modern slavery includes:

1. Slavery — the behaviour on the part of the offender as if they owned the victim, depriving the victim of their freedom;
2. Forced or compulsory labour — work or service of a victim which involves coercion, either direct threats or violence or more subtle forms of compulsion. Work or service is extracted from the victim under the menace of any penalty and for which the victim has not offered themselves voluntarily; and
3. Human trafficking — arrangements for the travel of the victim with a view to them being exploited.

It is important to recognise that modern slavery is prevalent throughout the world and whilst less common, exists in the United Kingdom and other developed countries.

3. Response to Modern Slavery

The Company will not tolerate any form of modern slavery within its own operations or within its supply chains.

You should notify the COO as soon as possible if you have any concerns, issues or suspicions about modern slavery in any parts of the business or its supply chains.

The Company aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. The Company is committed to ensuring that no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of the Company’s business or its supply chains.

4. Modern Slavery and the Essentia Supply Chain

The Company deploys processes to assess and validate its suppliers in accordance with the requirements of ISO 27001 prior to entering into any agreement. This includes obtaining confirmation from our suppliers that they have an anti-modern slavery policy in place.

In addition the Company reviews the potential for risk at regular intervals, including the possibility of re-auditing a supplier.

5. Information and Training

This policy forms part of the Company’s Employee Handbook and Contractor Handbook which is distributed to and acknowledged by each individual employee or contractor. All employees and contractors are expected to read this Policy.

Where appropriate, training is available to those most likely to interact with suppliers with a potentially higher risk of modern slavery.

6. Responsibility for This Policy

This policy is reviewed annually by the Board of Directors.