�. POLICY STATEMENT
1.1 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.
1.2 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. We expect the same high standards
from all of our contractors, suppliers and other business partners, and 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, and we expect that our
suppliers will hold their own suppliers to the same high standards.
1.3 This policy applies to all persons working for us or on our behalf in any capacity, including
employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns,
agents, contractors, external consultants, third-party representatives and business partners.
1.4 This policy does not form part of any employee’s contract of employment and we may amend
it at any time.
�. RESPONSIBILITY FOR THE POLICY
2.1 The board of Directors has overall responsibility for ensuring this policy complies with our
legal and ethical obligations, and that all those under our control comply with it.
2.2 The Compliance Manager has primary and day-to-day responsibility for implementing this
policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing
internal control systems and procedures to ensure they are effective in countering modern
slavery.
2.3 Management at all levels are responsible for ensuring those reporting to them understand
and comply with this policy and are given adequate and regular training on it and the issue of
modern slavery in supply chains.
2.4 You are invited to comment on this policy and suggest ways in which it might be improved.
Comments, suggestions, and queries are encouraged and should be addressed to the compliance
manager.
3. COMPLIANCE WITH THE POLICY
3.1 You must ensure that you read, understand, and comply with this policy. 3.2 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. You are required to avoid any
activity that might lead to, or suggest, a breach of this policy. 3.3 You must notify a representative
of the Management Team by email to compliance@h2ologistics.co.uk as soon as possible if you
believe or suspect that a conflict with this policy has occurred, or may occur in the future. 3.4 You
are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of
our business or supply chains, at any supplier tier, at the earliest possible stage. 3.5 If you believe
or suspect a breach of this policy has occurred or that it may occur you must notify the
compliance manager as soon as possible. 3.6 If you are unsure about whether a particular act, the
treatment of workers more generally, or their working conditions within any tier of our supply
chains constitutes any of the various forms of modern slavery, raise it with the Operative Care
Team in the first instance, who will report, investigate and escalate if necessary. 3.7 We aim 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. We are committed to ensuring 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 our own business or in any of our supply
chains. Detrimental treatment includes dismissal, disciplinary action, termination of a contract
for services, threats or other unfavourable treatment connected with raising a concern. If you
believe that you have suffered any such treatment, you should inform a representative of the
Management Team immediately. If the matter is not remedied, and you are an employee of H2O,
you should raise it formally using our Grievance Procedure.
4. COMMUNICATION AND AWARENESS OF THIS POLICY
4.1 Training on this policy, and on the risk our business faces from modern slavery in its supply
chains, forms part of the induction process for all individuals who work for, or provide services to
us, and training will be provided, as necessary.
4.2 Our zero-tolerance approach to modern slavery must be communicated to all suppliers,
contractors and business partners at the outset of our business relationship with them and
reinforced as appropriate thereafter.
�. BREACHES OF THIS POLICY
5.1 Any employee who breaches this policy will face disciplinary action, which could result in
dismissal for misconduct or gross misconduct.
5.2 We may terminate our relationship with other individuals and organisations providing
services to us if they breach this policy.