MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT
This statement has been published pursuant to the requirements under section
54 of the UK Modern Slavery Act 2015 and the California Transparency in Supply
Chain Act of 2010 and is Spectris plc’s modern slavery and human trafficking
statement for 2024. It provides information regarding the business practices ofSpectris plc, the holding company, its subsidiary companies, other companies
within the Spectris group 1 (together, “Spectris”/the “Group”), and the steps
Spectris has taken to ensure modern slavery and human trafficking (“MS&HT”) isnot taking place in its business and supply chains.
Spectris has a zero-tolerance approach to any form of modern slavery or humantrafficking. It is committed to acting ethically, with integrity and transparency inall business dealings and it is committed to implementing effective systems andcontrols to safeguard against any form of MS&HT in any part of its business oroperations. The Group considers that the risk of MS&HT taking place within its
business or direct supply chain is relatively low.
OUR BUSINESS STRUCTURE AND SUMMARY OF OUR OPERATIONS AND
SUPPLY CHAINS
Spectris is a diverse business, with over 7,000 employees in more than 30countries. We provide critical insights to our customers through premium
precision measurement solutions combined with technical expertise and deep
domain knowledge. Precision is at the heart of what we do - our leading, hightech instruments and software equip our customers to solve some of theirgreatest challenges to make the world cleaner, healthier and more productive.
Spectris is formed of two key divisions - Spectris Scientific and Spectris Dynamics,
which are placed in technology-driven end markets, with strong fundamentals
and attractive growth trajectories.
Our businesses are united by the same purpose, the same values and the same
corporate strategy. They all work according to a strong common framework ofcontrols, management KPIs, financial discipline and rigorous operating principles,but each business is focused on its own markets, customers and technologies.
We recruit, develop and promote our people based on their talent, commitment
and achievement; we continuously endeavour to ensure that everyone is treatedequally and fairly whatever their race, colour, religion, national origin, gender,sexual orientation, age, disability or background. Spectris is a very specialised andtechnical business, and we rely on the skills and expertise of our people, many ofwhom are highly qualified engineers and technicians.
A summary of the businesses covered by this statement is below:

1This statement sets out the steps taken by Spectris plc and the list of subsidiary companies set out in Appendix One.

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Spectris Scientific Division
Malvern Panalytical
Malvern Panalytical is a leader in the advanced measurement andcharacterisation of materials. The company provides best-in-class sensor
technologies, insightful data science and domain knowledge. They create
superior solutions to accelerate innovation and deliver greater efficiency in R&Dand manufacturing.
Particle Measuring Systems
Particle Measuring Systems specialises in particle counters that measure andmonitor contamination levels in clean and controlled environments. With morethan 60 patents, PMS create the technology that enables customers to makefact-based decisions, improve process yield and comply with changing regulatory
requirements.
Servomex
Servomex is a leading supplier of gas analysers (for use in both hazardous andsafe area applications) gas analysis systems and transducers, combined with a fullrange of customer support products and services.
Spectris Dynamics Division
HBK
HBK provides a strongly differentiated and integrated physical sensing, testing,modelling and simulation solution which helps customers create leading
products and accelerate product development. By delivering reliable precision
through technologies that integrate the physical and virtual domains, developers
can gain unprecedented insight into their product data and processes.
Our Supply Chains
Due to Spectris’ diverse business activities, it has a diverse supply chain.
Spectris is committed to preventing MS&HT in its corporate activities, and toworking with its supply chain to achieve this commitment. Spectris is committed
to promoting responsible business practices with our suppliers as outlined in
more detail below. Our objective is to build long-term stakeholder value by
supplying productivity-enhancing solutions and services for our customers. To
achieve this, we need a global high-performance supply chain.
Spectris has high standards of business conduct applicable to the wholeorganisation. We govern the actions of our company and employees and holdthem to the highest level of ethical and social accountability. Our goal is to workwith suppliers who embrace and comply with the same principles as our own.
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Spectris places high priority on compliance with the legislative and ethicalrequirements of the countries in which we operate, particularly with respect toemployment practices, labour rights and equal opportunities. The Spectris plc HR
Director has overall responsibility for employment policies, but responsibility for
implementation is delegated to individual businesses, with operational policies
and procedures tailored to suit local needs.
POLICIES RELEVANT TO MODERN SLAVERY AND HUMAN TRAFFICKING
Our Business
Spectris has several Group wide policies in place which address its MS&HT
compliance requirements and standards. Details of these policies are outlined
here.
Spectris maintains and issues policies and guidance at a Group level so that it canstandardise and maintain oversight of the interactions that companies have with
their suppliers. In the event that local legislation prevents compliance with Grouppolicies and guidance (which is expected to be rare), businesses are required toexplain their non-compliance and proposed mitigating actions and ensure thatthey have a dispensation from Spectris plc in place.
Wherever possible Spectris uses a standardised sourcing agreement which
includes key principles and values expected of suppliers. The standardisedsourcing agreement is then tailored to specific laws governing the jurisdictions inwhich the Spectris group companies operate.
Our Human Rights Policy is consistent with the Core Conventions of theInternational Labour Organisation. Spectris aims to comply with internationallyrecognised human rights standards at all of our sites. We operate a number ofadditional internal policies to ensure that we are conducting business in an
ethical and transparent manner. The internal policies include:-Code of Business Ethics: Our Code of Business Ethics makes clear toemployees the actions and behaviours expected of them whenrepresenting the organisation. Our Code was updated in 2020 and includes
specific safeguards against MS&HT. The Code also includes a robust
approach to anti-bribery and corruption. The organisation strives tomaintain the highest standards of employee conduct and ethicalbehaviour when operating abroad and managing its supply chain. The
Code of Business Ethics can be found here. In 2023, refresher training on
the Code of Business Ethics was carried out across the Group.

-Third Party Policy & Procedures: mandates the standards and proceduresthat all employees shall follow to appoint, manage, pay and terminate any
third parties that Spectris and its businesses engage;

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-Speak Up Policy: We encourage all workers, suppliers, customers and otherbusiness partners to report any concerns related to the direct activities, orthe supply chains of the organisation. This includes any circumstances thatmay give rise to an enhanced risk of MS&HT. The organisation's Speak Upprocedure is set out in Our Code of Business Ethics and is designed tomake it easy for workers to make disclosures, without fear of retaliation.
Employees, customers or other stakeholders and third parties who haveconcerns can use the Spectris confidential helpline(www.spectrishelpline.com). The helpline can be used to report violationsof the Code of Business Ethics including MS&HT in any Spectris entity andin any jurisdiction in which it operates. Concerns can be raised by filling out
an online form or dialling the confidential helpline numbers found on thewebsite; and-Supplier Code of Conduct: The Spectris Supplier Code underlines ourcommitment to ethical business practices and sustainable supply chains.
The Supplier Code serves as the foundation of our operations, outlining theminimum standards we expect from our valued supply chain partners andhow we would like them to work with us to fulfil our wider sustainability
ambitions. The Code outlines our commitment to integrity, transparency,and responsibility and it provides a comprehensive framework that guides
our interactions with suppliers and reinforces our core values of Own It, Be
True and Aim High. The Supplier Code works in tandem with Our Code ofBusiness Ethics, creating a robust foundation for our business practices.
Our Code was published in December 2023. We are confident that bycollectively embracing the standards in our Supplier Code with our supply
chain, we will strengthen our global impact and reinforce our position as aleading, sustainable business.

Supply Chain ManagementWe believe that suppliers, and other business partners, should have theopportunity to benefit from their relationship with us. In practice this means that
we aim to work together to minimise and manage business risk and improvebusiness practices, through education, training and the sharing of good practice.
Our Supplier Code of Conduct outlines the requirements we have of our suppliers
which include a commitment to:--Uphold and demonstrate high standards of integrity, governance andbusiness practice;
Ensuring that all work is voluntary. Forced, bonded (including debtbondage) or indentured labour, involuntary or exploitative prison labour,
slavery or trafficking of persons is not permitted.
Ensuring no unreasonable restrictions on workers’ freedom of movement
including the requirement to lodge deposits or identity papers.
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Providing all workers with clear and understandable information regarding
their employment and all disciplinary matters must be appropriatelyrecorded.
Not employing any person under the age for completing compulsory
education, or under the minimum age for employment in the country,
whichever is highest, save for the use of legitimate apprenticeships which
comply with relevant laws and regulations;
Verifying the age of workers using an appropriate process;Providing working conditions which meet Spectris’ high standards on
health, safety, hygiene and environmental practices;
Paying wages and benefits which meet or exceed which meet or exceed
national minimum requirements and adhere to working time regulations
where applicable;
Comply with Spectris’ standards and procedures in relation to anti-bribery
and corruption;
Not deny access to, or apply unfairly, a transparent grievance procedure;Not use any form of unlawful discrimination, harassment, abuse orbullying;
Be equally demanding of their suppliers and be able to demonstratecompliance to all of the aforementioned requirements; andDUE DILIGENCE AND SUPPLY CHAIN VERIFICATION, AUDITING AND
CERTIFICATION
In addition to due diligence processes, Spectris conduct on-site visits toinvestigate the specific operations of key suppliers. This allows Spectris to analysea supplier’s specific practices and procedures. Where risks are identified by ouron-site team during these visits this may lead to further investigations andpotentially a full audit. New and potential suppliers are made aware of theSpectris compliance framework.
RISK ASSESSMENT
Spectris is committed to identifying and preventing all forms of MS&HT in ourbusiness and to also supporting our supply chain in achieving the same goal. To
this end, we implemented robust risk assessment procedures. For example, oneof our entities screens for public information on our key suppliers, using thecloud-based Risk-Management solution “Sphera.” On-site visits and/or audits areundertaken. The Spectris DD toolkit is used for the evaluation of sales channel
partners and the Dow Jones RiskCenter tool is used by some businesses to verify
and monitor them.
The Group has assessed its supply chain against the top twenty countries
identified in the Global Slavery Index to assess the geographical risks of modern
slavery and human trafficking in the Group’s supply chain. Based on thisassessment, the Group has focused attention on its manufacturing operations
and key suppliers in China and South East Asia to ensure compliance with theUNRESTRICTED DOCUMENT5SA8000 Social Accountability Standard (SA 8000). The Group has trainedemployees in the Spectris Asia Pacific supply chain to review and supportcompliance with SA8000 and key suppliers have been audited against theSA8000 standard by the certified auditors to ensure that they have attained thecertification standard.
MODERN SLAVERY & HUMAN TRAFFICKING TRAINING
Spectris recognises that all supply chain management staff within theorganisation working in all countries need to complete risk-based MS&HTtraining. Spectris does undertake regular refresher training on the Code ofBusiness Ethics which includes training on fair employment, human rights andworking with partners and suppliers. In 2021, comprehensive risk-based training
on modern slavery and human trafficking was rolled out across Spectris toindividuals who have direct contact with the Group’s supply chain.
FUTURE STEPS/ ANY OTHER ACTIONS
Following the publication of our Supplier Code of Conduct, in FY2024, we willcontinue to refine and improve our procedures for the identification andprevention of MS&HT.
APPROVALThis statement has been examined and approved by the Board of Spectris plc on23 May 2024.
Mark Williamson
ChairmanSpectris plc

Andrew Heath
Chief Executive
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Appendix One
This statement relates to Spectris plc (UK Company Number 02025003) and thefollowing subsidiary companies:••••••

Spectris Group Holdings Limited, incorporated in England and Wales(01104312)
Malvern Panalytical Limited, incorporated in England and Wales (01020602)
Hottinger Brüel & Kjaer GmbH, incorporated in Germany (HRB 1147)
Hottinger Brüel & Kjær A/S incorporated in Denmark (CVR23958414)
Particle Measuring Systems Inc, incorporated in Colorado, US (19871264849/ 84-0645631)
Servomex Group Limited, incorporate in England and Wales (02170458).

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