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Anti Slavery and Human Trafficking

Introduction from Michael Edwards, Managing Director

We are committed to taking steps to combat slavery and human trafficking. The company has zero tolerance of modern slavery in its business and supply chain.

Our policies on slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

View Anti Slavery Statement

Due diligence processes for slavery and human trafficking
As part of our initiative to identify and mitigate risk we have in place systems to:
• Identify and assess potential risk areas in our supply chains. 
• Mitigate the risk of slavery and human trafficking occurring in our supply chains. 
• Monitor potential risk areas in our supply chains. 
• Protect whistle blowers.

Supplier adherence to our values
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have in place a supply chain compliance programme.

We have a dedicated compliance team, which consists of involvement from the following departments:
• Audit and compliance.
• Human resources.

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff.

Our effectiveness in combating slavery and human trafficking
We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
• Completion of audits by external provider
• Use of labour monitoring and payroll systems; and
• Level of communication and personal contact with next link in the supply chain and their understanding of, and compliance with, our expectations

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 30 June 2019.

Michael Edwards

Aviate Management Ltd.

02 July 2019

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