Modern Slavery Statement

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 & sets out the steps that Aquazone Ltd has taken & continues to take to ensure that modern slavery or human trafficking is not taking place within our business or our supply chain. Modern slavery encompasses slavery, servitude, human trafficking & forced labour. Aquazone Ltd has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically & with integrity & transparency in all our business dealings & to putting effective systems & controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

There are no areas of high risk within our business. Our supply chain consists of major suppliers with robust policies & procedures working within the European and international anti-slavery regulations. There is always of course some risk within our supply chain through their 3rd and 4th tier suppliers in the form of additional support staff (contract cleaners, caterers etc). These industries, providing labour in the lower wage brackets across the world can fall prey to management who encourage illegal immigrant labour, & “working cash in hand” in efforts to reduce overheads & increase profits. Aquazone Ltd will refuse to deal with any supplier who, in an effort to keep costs down, does not employ a full workforce being paid at least a minimum legal/living wage applicable for their country. Existing suppliers that come to our attention for providing illegal or lower than minimum wage labour will be investigated & may have their contract severed.

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

1. Anti-slavery policy: This policy sets out the organisation’s stance on modern slavery & explains how employees can identify any instances of this & where they can go for help.
2. 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.
3. Whistle blowing policy: We operate a whistle blowing 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.
4. Ethics Policy: This code explains the manner in which we behave as an organisation and how we expect our employees & suppliers to act.

• They have taken steps to eradicate modern slavery within their business.
• They hold their own suppliers to account over modern slavery.
• (For UK based suppliers) They pay their employees at least the national minimum wage / national living wage (as appropriate).
• (For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations.
• We may terminate the contract at any time should any instances of modern slavery come to light.

Aquazone Ltd operates a supplier policy & maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes various searches to ensure that a particular organisation has never been convicted of offenses relating to modern slavery & on-site audits which include a review of working conditions. Our anti-slavery policy forms part of our contract with all suppliers & they are required to confirm that no part of their business operations contradicts this policy.

In addition to the above, as part of our contract with suppliers, we require that they confirm to us that they are aware of, fully understand & agree to abide by our policy regarding Modern Slavery.

We regularly conduct training for specific personnel so that they understand the signs of modern slavery & what to do if they suspect that it is taking place within our supply chain.

This statement was approved by the Board of Directors on 3rd January 2023.

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