Anti-Slavery and Human Trafficking Policy

1. Background

This policy statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that
Connect Systems Ltd has taken, and is continuing to take, to ensure that modern slavery or human trafficking is
not taking place within our business or supply chain.

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

2. Our business

Connect Systems Ltd supplies and maintains networking infrastructure systems including managed services to
small and medium sized businesses in financial and investment services, independent schools and other industry
sectors. Offering a comprehensive range of quality products, our knowledgeable and technically trained staff
provide personal advice and practical solutions to meet networking requirements, from a straight forward cable to
a fully configured system. We work in partnership with many of the industry’s leading technology companies. We
operate solely within the UK.

3. Our high risk areas

Our risk relates to overseas procurement where we have little control over the recruitment and management of
employees or workers in other countries where the laws may not be so robust.

4. Our Anti-slavery and Human Trafficking Policy Statement

Connect Systems Ltd has a zero tolerance approach to any form of modern slavery. We are committed to acting
ethically and with integrity and transparency in all business dealings, and to putting effective systems and controls
in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

5. Our policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent
manner. These include:

  • Anti-slavery and Human Trafficking Policy. This policy sets out our stance on modern slavery;
  • Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the
    UK checks for all employees to safeguard against human trafficking or individuals being forced to work
    against their will;
  • Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise
    concerns about how colleagues are being treated, or practices within our business or supply chain, without
    fear of reprisals;
  • Code of business conduct. This code explains the manner in which we behave as an organisation and how
    we expect our employees and suppliers to act;
  • Approved Supplier and Contractor Vetting Procedure. We routinely vet our suppliers to ensure they meet
    our required standards is all aspects of the business.
6. Our suppliers

Connect Systems Ltd operates a supplier policy and maintains an approved supplier list. We conduct due diligence
on all suppliers before allowing them to become an approved supplier.

In addition to the above, as part of our contract with suppliers, we expect our suppliers to:

  • Have taken steps to eradicate modern slavery within their business;
  • Hold their own suppliers to account over modern slavery;
  • (For UK based suppliers) Pay their employees at least the national minimum wage / national living wage;
  • (For international suppliers) Pay their employees the prevailing minimum wage applicable within their
    country of operations;
  • We will terminate the contract at any time should any instances of modern slavery come to light.
7. Training and communication

As a small business we draw our employees’ attention to the Modern Slavery Act and ensure that our procurement
team understand the signs of modern slavery and what to do if they suspect that it is taking place within our
supply chain.

8. Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is
not taking place within our business or supply chain if no reports are received from employees, the public, or law
enforcement agencies to indicate that modern slavery practices have been identified.

9. Breaches of this policy

Any employee who breaches this policy will face disciplinary action, which may result is dismissal for misconduct
or gross misconduct – See QPG700 Staff Handbook.

Any individual or organisation working on our behalf breaching this policy will have their contract or agreement
terminated, and the appropriate authorities will be notified.

10.0 Related Documents

QPG700 – Staff Handbook
QP82.5 – Approved Supplier and Contractor Procedure

11.0 Related Legislation & Standards

Modern Slavery Act 2015
National Minimum Wage Act 1998
The National Minimum Wage Regulations 1999 (as amended)