Modern Slave Policy

1. Policy Statement

Zartec is committed to conducting business with the highest ethical standards and integrity. We have a zero-tolerance approach to any form of modern slavery or human trafficking. We are committed to ensuring that modern slavery is not present in our operations or supply chains.

This policy outlines the actions and steps Zartec takes to identify and prevent modern slavery, forced labour, and human trafficking within our operations and supply chains, in compliance with the Modern Slavery Act 2015.

2. Scope of the Policy

This policy applies to all employees, contractors, suppliers, and other business partners of Zartec. It covers all of our operations, including those in the UK and any international operations.

3. Our Commitment

Zartec takes a proactive approach to identifying, preventing, and addressing modern slavery and human trafficking risks. Our commitment includes the following:

• Zero-Tolerance: We have a strict zero-tolerance policy towards modern slavery, forced labour, child labour, and human trafficking.

• Due Diligence: We conduct due diligence on our supply chains and business relationships to ensure that modern slavery is not taking place.

• Training and Awareness: We provide training and guidance to our employees, contractors, and suppliers to ensure that modern slavery is clearly understood, and that they can identify and report concerns.

• Monitoring and Reporting: We monitor compliance with this policy and encourage employees, suppliers, and partners to report any concerns they may have without fear of retaliation.

4. Risk Assessment

As part of our commitment to preventing modern slavery, we regularly assess the risk of modern slavery in our operations and supply chains. This includes:

• Identifying high-risk areas, such as industries or regions where modern slavery is more prevalent.

• Reviewing our supply chains to ensure that we have effective controls in place.

• Evaluating existing suppliers and contractors to ensure they comply with our expectations regarding ethical conduct.

• Investigating any instances where modern slavery is suspected or reported.

5. Our Supply Chain

Zartec is committed to working with suppliers and contractors who share our commitment to ethical business practices. We have included specific terms in our supplier contracts and agreements that require them to comply with the Modern Slavery Act and to ensure that modern slavery, human trafficking, and forced or child labour are not present in their operations or supply chains.

• We expect our suppliers to have their own policies and procedures in place to prevent modern slavery.

• We reserve the right to audit suppliers and subcontractors to ensure that they are complying with this policy.

• If any supplier or partner is found to be in violation of this policy, Zartec will take appropriate action, which may include ending the relationship.

6. Recruitment Practices

We are committed to fair and ethical recruitment practices. We ensure that all of our employees are employed freely and have voluntarily agreed to their employment terms.

• We do not engage in any form of forced, bonded, or child labour.

• We ensure that our recruitment processes comply with UK employment laws and best practices.

• We ensure that all employees are paid fairly and on time, in compliance with the UK National Minimum Wage and National Living Wage.

7. Employee Awareness and Training

Zartec provides training to all employees and relevant stakeholders on the identification of modern slavery and human trafficking, how to report concerns, and the importance of following this policy.

Training includes:

• Recognizing the signs of modern slavery in the workplace and in supply chains.

• Understanding how to report suspected modern slavery cases.

• The importance of compliance with UK labour laws and the Modern Slavery Act 2015.

8. Reporting Mechanisms

We encourage all employees, suppliers, and contractors to report any concerns they may have regarding modern slavery or human trafficking. Zartec provides confidential reporting channels, including:

• Whistleblowing Policy: Employees can report concerns via our confidential whistleblowing system, either by email, phone, or through an online portal.

• Direct Contact: Concerns can also be reported directly to the management team at Zartec or via the Human Resources department.

We take all reports seriously and will investigate them thoroughly. Any reports of modern slavery will be handled with confidentiality and in accordance with our grievance and whistleblowing procedures.

9. Compliance and Monitoring

Zartec will regularly monitor and review the implementation of this policy, including carrying out audits on our supply chains to assess compliance with the Modern Slavery Act 2015.

If we identify any areas where improvements are needed, we will take appropriate action to ensure that modern slavery is eradicated from our operations and supply chains.

10. Policy Review

This Modern Slavery Policy will be reviewed annually to ensure that it remains effective, compliant with the Modern Slavery Act 2015, and relevant to the risks associated with modern slavery in our operations and supply chains. Any updates to this policy will be communicated to all employees and stakeholders.