Modern Slavery Statement

Modern Slavery and Human Trafficking Statement

Modern slavery is a crime and 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 aperson’s liberty by another in order to exploit them for personal or commercial gain. We are committed to actingethically and with integrity in all our business dealings and relationships and to implementing and enforcingeffective systems and controls to ensure modern slavery is not taking place anywhere in our business. 

Aims

Group First Global Limited is committed to conducting business in an ethical manner, upholding basic human rights in all its operations so that its staff and workers including those of its supply chain are not subject to
behaviour or threats that amount to modern slavery, human trafficking or forced labour.
This policy applies to all persons working for us or on our behalf including employees at all levels, directors, officers, agency workings, agents, contractors etc. This policy does not form part of an employee’s contract of employment and we may amend it at any time.

Managing Risk and Compliance

The Directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations,and that all those under our control comply with it. The directors all have a day-to-day responsibility forimplementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditinginternal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring those reporting to them understand and comply with thispolicy and for maintaining awareness of the issue of modern slavery in supply chains.

We expect our suppliers to hold their own suppliers to the same high standards.

We have evaluated the nature and extent of our exposures to the risk of slavery and human trafficking occurringin our UK supply chains through online internet checks of our suppliers, review of their modern slaverystatements, regular tendering process to ensure market rates and where possible onsite premises visit with keysuppliers.

We consider that we operate in a low-risk environment because of the business sector that we operate within.

Due Diligence Processes

The Company undertakes due diligence when considering new suppliers, encourages long-standing

relationships, and makes clear our commitment to responsible corporate behaviour in all business activities.We would consider invoking sanctions against suppliers that fail to improve their performance in line withexpected standards. This Includes

•  Identify and assess potential risk areas in our supply chains;

•  Protect whistle blowers

•  Ensuring that all internal processes are being adhered to for example ensuring that personnel have a Right to Work in the UK.

Our Policies

Group First Global Limited Modern Slavery Policy, along with our Anti-Bribery, Anti-Tax Evasion, Whistle-Blowingand Equal Opportunities policies demonstrate our commitment to acting ethically and with integrity in all ourbusiness relationships.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal.

We may terminate our relationship with other individuals and organisations working on our behalf if they breachthis policy.

Our Procedures

In order to assess the risk of modern slavery, we plan to implement the following processes:

• Identify and assess potential risks when taking on new suppliers

• Regular reviews of our existing supply chains

• Protection for whistle blowers

We have not identified any significant risks of modern slavery, forced labour, or human trafficking in our supplychain.

Training for Staff

To highlight awareness of modern slavery and human trafficking the Modern Slavery Policy has been included inthe employee handbook.

Periodic Review

This policy will be reviewed annually or more frequently in the event of any changes to statutory requirements orany evidence that the policy is not fully effective. There have been no breaches or suspected breaches of ourAnti-Slavery and Human Trafficking Policy reported in 2020.

This statement has approved by the Board of Directors on 1st September 2021, for financial year ending 30thJune 2021.

Signed by Ruth Almond (Director) on behalf of Group First Global Limited