Modern Slavery Statement In order to comply with the Modern Slavery Act 2015 the Gael Force Group have developed a policy as set out below. 1. Introduction Modern slavery can take various forms, such as servitude, forced or compulsory labour and human trafficking. Gael Force has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity and transparency in all of our business dealings and relationships. We are also committed to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within our business or supply chains, consistent with our obligations under the Modern Slavery Act 2015. Gael Force also expects the same high standards from all of our suppliers, contractors and other business partners and, as part of our contracting processes, we include specific prohibitions against the use of modern slavery, and expect that our suppliers will in turn hold their own suppliers to the same standards. Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many different ways. There is a spectrum of abuse and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness become instances of human trafficking, slavery or forced labour in a work environment. In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour. However, Gael Force accepts that we have a responsibility through our management system processes to ensure that workers are not being exploited, that they are safe and that relevant employment, health and safety and human rights laws and standards are being adhered to. This policy applies to all individuals working for Gael Force or on the Company’s behalf in any capacity, including employees, directors, officers, agency workers, volunteers, agents, contractors, consultants and business partners. 2. Responsibility for the policy The Group Managing Director has overall responsibility for ensuring that this policy complies with the Company’s legal and ethical obligations. The Quality department in cooperation with the Human Resources department has day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery. They are also responsible for investigating allegations of modern slavery in the Company’s business or supply chains. Line managers are responsible for ensuring that those reporting to them understand and comply with this policy. 3. Compliance The prevention, detection and reporting of modern slavery in any part of the Company’s business or supply chains, whether in the UK or abroad, is the responsibility of all those working for the Company or under the Company’s control. You are required to avoid any activity that might lead to a breach of this policy. If you believe or suspect a breach of or conflict with this policy has occurred or may occur, you must notify your line manager. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of the Company’s business or supply chains as soon as possible. If you are unsure about whether a particular act, the treatment of workers or their working conditions within any of the Company’s supply chains constitutes any of the various forms of modern slavery, please raise it with your line manager. You can also contact the government’s Modern Slavery Helpline on 0800 0121 700 for further information and guidance on modern slavery. The Company aims 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. The Company is committed to ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of its business or in any of its supply chains. 4. Training and communication Explanation or Training on this policy and on the risk that the business faces from modern slavery in its supply chains, will be provided to staff as necessary, so that they know how to identify exploitation and modern slavery and how to report suspected cases. The Company’s zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and other business partners when entering into new or renewed contracts with them. 5. Breach of the policy Any employee who knowingly breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct. The Company may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery. Individual Line Managers/Supervisors are responsible for ensuring that this policy and related procedures are applied within their own area. The HR Department should be consulted before action is taken and can be contacted to answer any queries relating to the application or interpretation of this policy. This policy will be reviewed on a regular basis and the Company reserves the right to change any of the provisions set out in this document from time to time, as may be required. Stewart Graham Group Managing Director Head Office Gael Force Group Limited Anderson Street Inverness Scotland, IV3 8DH. +44 (0)1463 229400 sales@gaelforcegroup.com Media & Resources Locations Case Studies Legal Terms & Conditions Privacy Policy & Cookies Feedback & Complaints Modern Slavery Statement © 2021 Gael Force Group Limited.