Introduction

Butler Fox is committed to operating with integrity and high ethical standards. This includes ensuring that our business respects human rights

Butler Fox Ltd does not tolerate modern slavery or human trafficking in any part of our business or our supply chains. The Butler Fox Ltd Human Rights Statement asserts our responsibility to respect the rights of all people. This commitment to respecting human rights is underpinned in our policies, our values and in our relationships with third parties. Our Code of Ethics defines our values at work and guides our behaviours. We require our employees to interact with others in an ethical and proper manner and highlights our employment principles and other ethical standards. It specifically prohibits the use of modern slavery or human trafficking in our business. The Butler Fox Ltd Expectations of Third Parties policy and Vendor Code of Conduct also inform our third parties that we do not tolerate the use of child labour and forced labour by third parties.

Statement

Modern Slavery Policy 

1. Introduction 

Butler Fox Ltd is committed to preventing modern slavery and human trafficking in all its business activities and supply chains. This policy outlines our approach to ensuring that modern slavery does not occur within our organisation or our supply chains. 

2. Scope 

This policy applies to all individuals working for Butler Fox Ltd or on our behalf in any capacity, including employees, directors, officers, agency workers, contractors, consultants, and business partners. 

3. Definitions 

• • Modern Slavery: Encompasses slavery, servitude, forced and compulsory labour, and human trafficking. 

• • Human Trafficking: The recruitment, transportation, transfer, harbouring, or receipt of persons by means of threat, force, coercion, abduction, fraud, deception, or abuse of power for the purpose of exploitation. 

4. Our Commitment 

Butler Fox Ltd has a zero-tolerance approach to modern slavery. 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 business or supply chains. 

5. Organisational Structure and Supply Chains 

Butler Fox Ltd operates in the United Kingdom and has 4 employees. Our supply chains include cloud services suppliers located in the UK. 

6. Policies and Procedures 

We have implemented the following policies and procedures to prevent modern slavery: 

• • Recruitment Policy: Ensures fair recruitment practices and prevents forced labour. 

• • Supplier Code of Conduct: Requires all suppliers to adhere to our standards regarding modern slavery. 

• • Whistleblowing Policy: Encourages employees to report any concerns related to modern slavery. 

7. Due Diligence Processes 

We conduct due diligence on all suppliers and business partners to ensure compliance with our modern slavery policy. This includes: 

• • Risk assessments to identify areas of potential risk. 

• • Audits and inspections of suppliers. 

• • Requiring suppliers to provide evidence of their own anti-slavery measures. 

8. Training and Awareness 

We provide training to all employees to ensure they understand the risks of modern slavery and how to identify and report potential cases. This includes: 

• • Induction training for new employees. 

• • Regular refresher training sessions. 

• • Access to resources and support for reporting concerns. 

9. Reporting and Monitoring 

We have established mechanisms for reporting and monitoring compliance with this policy: 

• • Reporting: Employees and stakeholders can report concerns through our confidential reporting system. 

• • Monitoring: Regular reviews of our policies and procedures to ensure effectiveness. 

10. Responsibility for the Policy 

The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations. The compliance team is responsible for implementing and monitoring the policy. 

11. Review and Updates 

This policy will be reviewed annually and updated as necessary to reflect changes in legislation or our business operations. 

Communication & awareness of this policy

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, and updates will be provided using established methods of communication between the business and you.

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. Breaches of this policy

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

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Signed Off By: Chris Butler, Director, July 2024