Anti-Slavery Policy

Introduction

Modern slavery is a crime and violation of fundamental human rights. It takes various forms, such as slavery,
servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a
person’s liberty by another in order to exploit them for personal or commercial gain.

We have a zero-tolerance approach and are committed to acting ethically and with integrity in all our business
dealings and relationships and to implementing and enforcing procedures to ensure modern slavery is not taking
place anywhere in our own business or in any of our supply chains.

Organisation Structure

Smarter Technologies Group Limited is a limited company registered in England and Wales, with Company
Registration number 12075211.

Our Business

Our principal activities are to assist with all aspects of Digital Transformation required within the public sector
markets, with clients ranging from Central to Local Government, MoD, DEFRA, DTI, NHS Trusts. Our annual
turnover is in excess of £14m. To find out more about Smarter Technologies Group Limited please visit
smartertechnologies.com

Our Supply Chain

In order to provide services to our clients we work with a range of suppliers including, but not limited to,
professional service firms, utility suppliers, IT vendors, consultants, industry business partners and technology
platform providers.

Our Policy 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 Statement reflects our commitment to acting ethically and with integrity in
all our business relationships and in relation to implementing and enforcing effective systems and controls to
ensure slavery and human trafficking is not taking place anywhere in our supply chains.

We also make sure our suppliers are aware of our policies and adhere to the same high standards.

Due Diligence Processes for Slavery and Human Trafficking

As part of our initiative to identify and mitigate risk we have in place systems, due diligence processes and
procedures to:

  • Mitigate the risks in recruitment (through our recruitment and vetting policies). We conduct eligibility to
    work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to
    work against their will.
  • Identify, assess and monitor potential risk areas in our supply chains.

Reduce the risk of slavery and human trafficking occurring in our supply chains; and

  • Encourage and protect whistle blowers.

Supplier Adherence to our Values

We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain to comply with
our values. For example, if we find evidence of a failure to comply with our policies which contain or reflect antislavery
measures, we will immediately seek to terminate our relationship with the relevant supplier.

Training

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 regular training to our staff.

Our effectiveness in Combating Slavery and Human Trafficking

We intend to use key performance indicators (KPls) 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. This statement is
made pursuant to section 54(I) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking
statement for the current financial year.

Ed Walker
Director, Smarter Technologies Group Limited
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