CONVIVIALITY PLC ANTI-SLAVERY AND HUMAN TRAFFICKING POLICY

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1 CONVIVIALITY PLC ANTI-SLAVERY AND HUMAN TRAFFICKING POLICY INTRODUCTION 1. The Modern Slavery Act 2015 ( MSA ) came into force on the 29 th October The MSA consolidated previous law and strengthened penalties for the offences of slavery, servitude, forced or compulsory labour and human trafficking. 3. Individuals who breach the MSA are subject to imprisonment and/or unlimited fines. 4. A breach of the MSA by Conviviality PLC or any of its subsidiaries could lead to an injunction by the Secretary of State to force compliance and/or unlimited fines as well as damage to reputation and loss of business. 5. The Board of Directors of Conviviality PLC has a clear and unambiguous commitment to comply with the MSA. 6. This Policy is to ensure that the MSA will not be breached by Conviviality PLC or its subsidiaries by:- a. Explaining the relevant provisions of the MSA and the approach to be taken in respect to it; and b. Making sure that adequate procedures are put in place to comply with the MSA. 7. As well as Conviviality PLC, Conviviality Retail, Conviviality Direct and Conviviality Trading and Logistics must adopt this Policy. The Group People Director of Conviviality PLC will be responsible for implementing and monitoring the Policy at Conviviality PLC and may appoint others to help as appropriate. The Managing Directors of Conviviality Retail, Conviviality Direct and Conviviality Trading will be responsible for implementing and monitoring the Policy in their division and the Group Logistics and Distribution Director for implementing and monitoring the Policy across Logistics and each may appoint others to help as appropriate. 8. Any employee who breaches this Policy will face disciplinary action, which could result in dismissal for gross misconduct.

2 2 SECTION 1 - EXPLANATION OF THE MSA AND THE APPROACH TO IT The sections below explain the MSA and the Conviviality PLC approach to it Effective date The MSA came into force on the 29 th October Modern slavery Zero tolerance Responsibility Specific legal offences Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, 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. Conviviality PLC and its subsidiaries have a zerotolerance approach to modern slavery and are committed to acting ethically and with integrity in all business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place. The prevention, detection and reporting of modern slavery in any part of the business or supply chains is the responsibility of all those working for Conviviality PLC and its subsidiaries. All such persons must avoid any activity that might lead to, or suggest, a breach of this Policy. The following are specific offences under the MSA:- 1. Slavery which involves behaviour on the part of the offender as if he/ she owns a person, which deprives the victim of their freedom. 2. Servitude which is the obligation to provide services that is imposed by the use of coercion and includes the obligation for a serf to live on another person s property and the impossibility of changing his or her condition. 3. Forced or Compulsory Labour which involves coercion, either direct threats of violence or more subtle forms of compulsion. The key elements is that work or service is exacted from a person under the menace of penalty and for which the person has not offered him/her self voluntarily. 4. Human trafficking which requires that a person arranges or facilitates the travel of another person with a view to that person being exploited whether or not that other person consents.

3 3 Risk review Training Business partners Compliance statement Raising concerns We will review our business to determine where there is a risk of modern slavery and human trafficking taking place and take steps to assess and manage that risk. We will ensure all our workers understand the relevant provisions of the MSA and our approach to it. We are committed to ensuring there is transparency in our approach to tackling modern slavery throughout our business. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we will include, where appropriate, 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. We will review our due diligence procedures in relation to modern slavery and human trafficking in our business and supply chain. We will also be subject to similar due diligence from our customers. Conviviality PLC will produce a statement on its web site each financial year signed by a Director that covers the steps that it and each division has taken during the previous financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains and in any part of its own business. Every website of each trading division will provide a link to this statement. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at the earliest possible stage. If you believe or suspect a breach of this Policy has occurred or that it may occur you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible. If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within our business or any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager.

4 4 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, threats or other unfavourable treatment connected with raising a concern. Recommended steps to be taken if modern slavery or human trafficking is identified Legal consequences of breaching the MSA If a specific case of modern slavery is identified in the UK, it should be reported to the police by or on behalf of the divisional Managing Director on 101. If potential victims are in immediate danger the standard 999 emergency number should be used by anyone. If a potential victim is identified they can be referred to the National Referral Mechanism to be formally identified as a victim of modern slavery and offered Government-funded support. If modern slavery is identified or suspected abroad, then the response should be tailored to the local circumstances by the Managing Director after consultation with legal counsel. We may terminate our relationships with other individuals and organisations working on our behalf if they breach the MSA or this Policy. Individuals who breach the MSA are subject to imprisonment and/or unlimited fines. A breach of the MSA by Conviviality PLC or any of its subsidiaries could lead to an injunction by the Secretary of State to force compliance, unlimited fines and damage to reputation and loss of business.

5 5 SECTION 2- ADQUATE PROCEDURES TO COMPLY WITH THE POLICY The sections below explain the steps and procedures which must be put in place by Conviviality PLC and Conviviality Retail, Conviviality Direct, Conviviality Trading and Logistics to comply with this Policy Carry out risk assessment Action for HR/People Teams 1. Consider the extent to which the business currently participates in existing programmes of activity relevant to the MSA such as:- a. The UN guiding Principles Reporting Framework; b. Non-financial reporting already required on human rights issues under the Companies Act 2006 (Strategic Report and Directors Report) Regulations 2013; and/or c. Under changes to EU Accounting Directive (2014/95/EU) in respect of financial years ending on or after 1 st January 2017 relating to environmental, social and employee matters, respect for human rights, anti-corruption and bribery matters. 2. Identify which parts of the business are most at risk of modern slavery and human trafficking. It is anticipated this will include (but not be limited to):- a. HR/People Teams; and b. Procurement/buying teams. 3. Assess the nature of the risks and the severity of them. 4. Ensure appropriate and proportionate action is taken regarding the risks identified and an adequate system of controls is put in place and tested. 5. Measure the effectiveness of the Policy in ensuring that modern slavery and human trafficking is not taking place in the business or supply chains measured against such performance indicators as are considered appropriate. Action taken in respect of risks to HR/People Teams must include (but not be limited to):- 1. Reviewing current policies and procedures for taking on new workers to flag warning signs of modern

6 6 slavery and human trafficking. Warning signs may include the inability of a new worker to produce a passport when required; and 2. Ensuring all existing and new workers understand the relevant provisions of the MSA and our approach to it by:- a. Providing existing workers with a copy of Section 1 of this Policy; and b. Ensuring a copy of Section 1 of this Policy is provided in the same way to all new workers. Action for procurement/buying/risk teams Action to be taken in respect of procurement/buying teams must include (but not be limited to):- 1. Mapping the supply chain - identifying those areas of particular risk and impact (for example country/regional risks as identified by the Walk Free Foundation s Global Slavery Index) initially concentrating on immediate relationships and then making recommendations on areas for improvement in addressing modern slavery and human trafficking hotspots and risks with suppliers; 2. Reviewing and improving pre-screening/due diligence processes - these processes should be reasonable and proportionate, reflecting the severity and likelihood of the risk, the size of the business and its resources, the nature and context of its operations and the capacity to stop harm. Questions could include but are not limited to assessing if the supplier; a. Has a policy on modern slavery and human trafficking; b. Complies with International/National/ Local Labour Laws; c. Follows the UN Guiding Principles (UNGP) on human rights due diligence? d. Pays workers a minimum wage; and e. Requires payment of a fee to work. The business should then integrate and act upon the findings, tracking responses, and communicating how impacts are addressed; 3. Engaging with suppliers - both to convey this Policy

7 7 and to gain an understanding of the measures taken by them to ensure modern slavery and human trafficking is not occurring in their business. This may include auditing by the business and/or selfreporting for suppliers; 4. Where appropriate introducing contractual provisions - for suppliers to confirm implementation of and adherence to a policy similar to this Policy including, if required, an ability for the business to terminate arrangements without liability for breach of this protection. 5. Establish a pro-forma response to customers who carry out due diligence on/seek comfort from us on the extent to which our business complies with the MSA. This should be limited to confirming our commitment to eradicating modern slavery and human trafficking, that we have a written MSA Policy, provide appropriate training and will issue a compliance statement each year (as described below). Compliance Statement Conviviality PLC must produce a statement on its web site each financial year that covers the steps that it has taken during the previous financial year to ensure that slavery and human trafficking is not taking place. A link should be included in a prominent place on its homepage. This statement will also include all the steps Conviviality Retail, Conviviality Direct and Conviviality Trading have taken to ensure that slavery and human trafficking is not taking place and their websites must include a link in a prominent place in their homepages to the statement. The statement is required on the website within 6 months of the end of each financial year. The first statement is required by 30 th September The General Counsel & Company Secretary will be responsible for co-ordinating this. The Modern Slavery Act does not prescribe the content of the statement, but says the following may be included:- - Its structure, business and supply chains; - Its policies in relation to modern slavery and human trafficking; - Its due diligence processes in relation to modern slavery and human trafficking in its business and

8 8 supply chains; - The parts of its business and supply chains where there is a risk of modern slavery and human trafficking taking place, and the steps that it has taken to assess and manage that risk; - Its effectiveness in ensuring that modern slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate; and - The training about modern slavery and human trafficking available to its staff. The statement must to be approved by the Board of Directors of Conviviality Plc and signed one of its Directors. Arrangements must be made for a statement to be drafted each year on behalf of Conviviality PLC and for Conviviality Retail, Conviviality Direct, Conviviality Trading and Logistics to contribute to it in time for final board approval and signature and uploading to the website with the required links within the required timescales. Key policies and processes which support this Policy These may include by way of example only policies in respect of:- Corporate Social Responsibility Ethical Trading Whistleblowing Employee Codes of Conduct Agency Worker Recruitment Process Procurement Policy/ Process

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