Modern Slavery & Human Trafficking Policy

HVW LTD is committed to ensuring that all business operations, supply chain activities and organisational practices actively prevent modern slavery, forced labour and human trafficking. We take a zero-tolerance approach to exploitation and work continually to promote transparency, ethical sourcing and responsible business conduct.

Our Commitment

We ensure that our supply chain, operations and employment practices are aligned with UK legislation, including the Modern Slavery Act 2015. Our goal is to safeguard workers, protect human rights and ensure full compliance with ethical labour standards.

• High ethical standards across all business operations.
• Promotion of Fair Trade, Sustainability and Human Rights.
• Robust recruitment processes including eligibility-to-work checks.
• Whistleblowing procedures enabling staff to report concerns safely.
• Clear expectations for staff and suppliers via our Code of Conduct.

Supplier Due Diligence

We monitor existing suppliers and assess new suppliers to ensure that labour exploitation is not present within our supply chain. Our due diligence includes:

• Mapping the supply chain to understand labour and sourcing risks.
• Conducting supplier audits and assessments where required.
• Identifying high-risk areas and implementing corrective actions.
• Educating suppliers on best practices for eliminating modern slavery.
• Participating in collaborative initiatives and industry discussions.

Risk Assessment & Management

Before onboarding or renewing supplier relationships, we evaluate the risks associated with geographic location, industry category, labour practices and subcontracting activity. These assessments allow us to:

• Identify potential vulnerabilities.
• Assess the level of severity and likelihood.
• Introduce and enforce appropriate control measures.
• Monitor improvements and ensure corrective actions are sustained.

Monitoring & KPI Performance

We regularly review our activities and measure performance against defined modern slavery objectives. Annual summaries and policy updates will be made available upon request or published on our website in accordance with transparency requirements.

Training & Awareness

Training is provided to employees, contractors and relevant stakeholders to ensure that modern slavery awareness is embedded within HVW LTD. Training methods include:

• Induction training and policy acknowledgement.
• Toolbox talks and internal workshops.
• Relevant online training modules.
• Seminars and industry events for managers and “at-risk” staff.

All training progress is recorded and monitored through our internal KPI systems.

Roles & Responsibilities

HVW LTD Responsibilities

• Maintain and update this Modern Slavery Policy.
• Identify and address modern slavery risks.
• Provide training and information to all relevant employees.
• Ensure supplier and contractor compliance with this policy.
• Continuously improve processes and controls.

Employee Responsibilities

• Follow the company policies relating to modern slavery and human trafficking.
• Participate in training and awareness activities.
• Report concerns to senior management immediately.
• Maintain compliance with the Whistleblowing Policy.

Whistleblowing & Reporting Concerns

HVW LTD encourages employees and partners to report any suspected human trafficking or modern slavery in the business or supply chain. Reports can be made confidentially without fear of reprisal and will be investigated thoroughly.

Policy Review

This statement is reviewed annually or following significant changes in legislation, supply chain structure or business operations. Updates are published to maintain full transparency.

Signed

John McCarrick
Managing Director
HVW LTD
Date: 10/10/2025