Introduction

Modern slavery can take various forms, such as, servitude, forced or compulsory labour and human trafficking. IBMG has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity and transparency in all our business dealings and relationships. We are also committed to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within our business or supply chains, consistent with our obligations under the Modern Slavery Act 2015.

We also expect the same high standards from all suppliers, contractors, and other business partners and, as part of our contracting processes, it includes specific prohibitions against the use of modern slavery and we expect that our suppliers will in turn hold their own suppliers to the same standards and account.

Objectives
Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many ways. There is a spectrum of abuse and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness have become instances of human trafficking, slavery or forced labour in a work environment. In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour.

However, we accept that we have a responsibility through our due diligence processes to ensure that workers are not being exploited, that they are safe, and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.

This policy applies to all individuals working for IBMG on the business behalf in any capacity, including employees, directors, officers, agency workers, volunteers, agents, contractors, consultants, and business partners.

Responsibility for the Policy
The IBMG Executive Team has overall responsibility for ensuring that this policy complies with the business' legal and ethical obligations.

The Group Commercial & HR functions have day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery. They are also responsible for investigating allegations of modern slavery in supply chains.

Line managers are responsible for ensuring that those reporting to them understand and comply with this policy.

Compliance
The prevention, detection and reporting of modern slavery in any part of our business or supply chains, whether in the UK or abroad, is the responsibility of all those working for us or under the business control. You are required to avoid any activity that might lead to a breach of this policy.

If an employee believes or suspects a breach of this policy has occurred or may occur, they must notify their
line manager. Employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business or supply chains as soon as possible through our whistleblowing hotline on whistleblowing@independentbm.com. If an employee is unsure about whether a particular act, the treatment of workers or their working conditions within any of the business' supply chains constitutes any of the various forms of modern slavery, this should be escalated using the whistleblowing process.

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 or victimisation as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of our business or in any of our supply chains.

Training and Communication
Regular training on this policy, and on the risk that the business faces from modern slavery in our supply chains, will be provided to employees as necessary, so that they know how to identify exploitation and modern slavery and how to report suspected cases.

Our zero tolerance approach to modern slavery must be communicated to all suppliers, contractors and other business partners when entering in to a new or renewed contract with them.

Breach of the Policy
Sanctions for breach of the policy include:

• Disciplinary action or dismissal if the breach is by a colleague/manager
• Termination of the contract if the breach is by a supplier, contractor, or other business partner

Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.

We may terminate our commercial relationship with suppliers, contractors, and other business partners if they breach this policy and/or are found to have been involved in modern slavery.

Review
This policy will be reviewed on a regular basis and updated as necessary in line with changes in current legislation.

Who can I speak to for further advice?

• Line Manager
• HR Department