Anti-Slavery & Human Trafficking Policy

1 Policy Statement
AD Modular Ltd have a zero-tolerance approach to modern slavery and 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 own business or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to
tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, staff agency workers, contractors, external consultants, third-party
representatives and business partners.
This policy does not form part of any employee’s contract of employment and we may amend it at any time.
2 Responsibility for the Policy
The directors have overall responsibility for ensuring this policy complies with our legal and ethical
obligations, and that all those under our control comply with it.
The Managing Director has primary and day-to-day responsibility for implementing this policy, monitoring
its use and effectiveness, dealing with any queries about it, and auditing internal control systems and
procedures to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them understand and comply with
this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
You are invited to comment on this policy and suggest ways in which it might be improved. Comments,
suggestions and queries are encouraged and should be addressed to the Managing Director.
3 Compliance with the Policy
You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the
responsibility of all those working for AD Modular Ltd or under our control. You are required to avoid any
activity that might lead to, or suggest, a breach of this policy.
You must notify your manager or the Managing Director as soon as possible if you believe or suspect that a
conflict with this policy has occurred, or may occur in the future.
1 Policy Statement
AD Modular Ltd have a zero-tolerance approach to modern slavery and 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 own business or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to
tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, staff agency workers, contractors, external consultants, third-party
representatives and business partners.
This policy does not form part of any employee’s contract of employment and we may amend it at any time.
2 Responsibility for the Policy
The directors have overall responsibility for ensuring this policy complies with our legal and ethical
obligations, and that all those under our control comply with it.
The Managing Director has primary and day-to-day responsibility for implementing this policy, monitoring
its use and effectiveness, dealing with any queries about it, and auditing internal control systems and
procedures to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them understand and comply with
this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
You are invited to comment on this policy and suggest ways in which it might be improved. Comments,
suggestions and queries are encouraged and should be addressed to the Managing Director.
3 Compliance with the Policy
You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the
responsibility of all those working for AD Modular Ltd or under our control. You are required to avoid any
activity that might lead to, or suggest, a breach of this policy.
You must notify your manager or the Managing Director as soon as possible if you believe or suspect that a
conflict with this policy has occurred, or may occur in the future.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our
business or supply chains of any supplier tier at the earliest possible stage.
If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your
manager or report it to the Managing Director as soon as possible.
If you are unsure about whether a particular act, the treatment of workers, more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or the Managing Director.
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 as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own b u s i n e s s or in any of our supply chains.
4 Communication and 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 AD Modular Ltd, and regular training will be
provided as necessary.
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.
5 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 organisation’s working on our behalf if they
breach this policy.