1. Policy Statement

1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which involve the deprivation of a person’s liberty in order to exploit them for personal or commercial gain. At TechYard Limited we 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. We enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

1.2 We are committed to maintaining transparency in our business and in our approach to tackling modern slavery throughout our supply chains, in line with our obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our employees, consultants, suppliers, clients and business partners. Our contracting processes include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect suppliers and contractors to hold their own suppliers to these same standards.

1.3 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

1.4 This policy may be amended at any time.

2. Responsibility for the Policy

2.1 We have overall responsibility for ensuring this policy complies with our legal and ethical obligations and that all those under our control comply with it.

2.2 The Compliance Department is responsible for coordinating the company’s approach to preventing modern slavery and human trafficking. This includes maintaining compliance procedures, monitoring implementation across departments, and ensuring that appropriate reporting and investigation processes are in place. The department works closely with HR, Procurement and Executive Management to support training, supplier due diligence and ongoing review of this policy.

2.3 Management at all levels is responsible for ensuring their teams understand and comply with this policy and receive regular and adequate training on it and the issue of modern slavery in supply chains.

3. Compliance with the Policy

3.1 You must ensure that you read, understand and comply with this policy.

3.2 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 us or under our control. You must avoid any activity that might lead to or suggest a breach of this policy.

3.3 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at the earliest possible stage.

3.4 If you believe or suspect that a conflict or breach of this policy has occurred or may occur, you must notify our Compliance Department as soon as possible. Where appropriate, and with the welfare of local workers as a priority, we may support suppliers in addressing coercive or exploitative practices.

3.5 If you are unsure whether a particular act, treatment of workers, or working conditions in any tier of our supply chain constitutes modern slavery, you must raise it with the Compliance Department.

3.6 We encourage openness and will support anyone who raises genuine concerns in good faith, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting concerns. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment. If such treatment occurs, report it to the Compliance Department immediately. If unresolved and you are an employee, raise it formally under our Grievance Procedure, available from the HR Department.

4. Communication and Awareness of This Policy

4.1 Training on this policy, and on the risks our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals working for us. Additional training will be provided where necessary.

4.2 Our zero-tolerance approach to modern slavery must be communicated to all employees, consultants, suppliers, clients and business partners at the outset of any relationship and reinforced where appropriate thereafter.

5. Breaches of This Policy

5.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

5.2 We may terminate our relationship with any individual or organisation working on our behalf if they breach this policy.

6. Policy Review

We will review this policy annually to ensure compliance with new or amended laws, regulations or guidance. We will also monitor compliance regularly, including through audits.

All Rights Reserved ©AVUKE 2025. This policy is provided for TechYard Limited and is not to be reproduced, copied, or shared with any third-party providers other than for the sole purpose it was created for.