Slavery Act Policy

1.0 Modern Day Slavery

1.1 Modern day slavery, as defined by the Modern Day Slavery Act 2015, includes: human trafficking, slavery, servitude, forced and bonded labour and child labour. Midco regards modern day slavery as a violation of human rights. Midco is working to adopt the requirements of the UK Modern Day Slavery Act (2015) and play our role in protecting people from harm and exploitation. This statement demonstrates our commitment to tackle modern day slavery by raising awareness amongst our staff, suppliers, partners and customers.

1.2 Monitoring Supply Chains

The Modern Day Slavery Act 2015 requires all companies with a total annual turnover of £36 million pounds to detail what steps a company has taken to ensure that modern slavery is not occurring in the supply chain and within the company.

Midco does not meet the threshold required to produce an annual statement ensuring there is no modern slavery in our own business or supply chains.

1.3 Due Diligence and Risk Assessment

• As part of the due diligence process, Midco reviews our supply chain. We have a small number of regular suppliers. We are aware of the details of their suppliers and working conditions.

• We conduct routine assessments of their processes to identify any risks of modern day slavery or exploitation posed by the operations of our supply chain.

• We conduct due diligence in relation to our supply chain. We request copies of Modern Day Policy Statements from our customers, suppliers and partners.

1.4 Effective Action to Address Modern Day Slavery

• All Midco staff are made aware our approach to modern day slavery through Departmental Meetings where this policy is discussed to raise awareness of the kinds and signs of modern day slavery.

• In the event of any staff identifying any situations that could be regarded as incidents of modern day slavery in the supply chain. Midco staff collate the details of their concerns. They notify their relevant manager for further investigation.

• The relevant manager reports their findings to the Managing Director.

1.5 Reporting concerns of Modern Day Slavery and Trafficking

If anyone has any concerns that someone is being exploited within a supply company, they should discuss this with the Company General Manager. This enables Midco Management Team to review our work with that company. If staff or the Midco Management Team have any concerns that people are being exploited they must notify the

Modern Day Slavery Helpline on 0800 0121 700. Staff can also notify Crimestoppers anonymously on 0800 555 111.