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Modern Slavery Act Policy

Modern Slavery Act Policy

Slavery and human trafficking policy

1. Scope

1.1 This policy applies to all persons working for Everest or on our behalf in any capacity, without exception.

2. Policy statements

2.1 Everest has a zero-tolerance approach to modern slavery.

2.2 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.

2.3 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.

2.4 We expect the same high standards from all of our contractors, suppliers and other business partners. 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. Further, we expect that our suppliers will hold their own suppliers to the same high standards.

3. Responsibility for the policy

3.1 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.

3.2 The Head of Supply Chain 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.

3.3 Line managers 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.

3.4 All staff 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 Head of Supply Chain.

4. Compliance with the policy

4.1 Employees and contractors must ensure that they read, understand and comply with this policy.

4.2 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. All such persons are required to avoid any activity that might lead to, or suggest, a breach of this policy.

4.3 Anyone who believes or suspects that a conflict with this policy has occurred, or may occur in the future, must report it to a senior manager or director immediately.

4.4 Employees and contractors are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage. If 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, this should be raised with the Head of Supply Chain.

4.5 Everest encourages 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.

5. Communication and awareness of this policy

5.1 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 us or with us, and regular training will be provided as necessary.

5.2 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.

6. Breaches of this policy

6.1 Any employee who breaches this policy will face disciplinary action, which could result in summary dismissal for gross misconduct.

6.2 We will terminate our relationship with other contractors or organisations working on our behalf if they breach this policy.

7. Status

7.1 This policy does not form part of any contract of employment or engagement and the terms may be amended by Everest from time to time at its sole and absolute discretion.