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MODERN SLAVERY POLICY

The company acknowledges the provisions of the Modern Slavery Act 2015 and will ensure transparency within its organisation and with suppliers of goods and services to the organisation.

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 have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Vault has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implement and enforce effective controls to ensure modern slavery is not taking place anywhere in our own business or our supply chain.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain. We expect the same high standards from all our contractors, suppliers and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for Vault or on our behalf in any capacity, including agents, contractors, external consultants, third-party representatives and business partners as necessary.

The Directors and senior management team at the Company have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all persons working for us or on our behalf comply with it.

The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all persons working for us or on our behalf in any capacity.

The Company is satisfied from its own due diligence there is no evidence of any act of modern-day slavery or human trafficking within its own organisation.

Our Policy Statement is available to all employees and all employees are expected to read and understand it. This policy must be clearly and prominently displayed on the Notice Board at all business locations.

All persons working for us in any capacity must:

• Read, understand and comply with this policy, and avoid any activity that might lead to, or suggest, a breach of this policy.
• Notify their immediate Manager as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future.  We have systems in place for individuals to report concerns, anonymously if preferred, and to protect whistle-blowers.

The Company will review both its supply chain and internal operations on an annual basis to check compliance with the above policy, and to ensure that our policy is being implemented effectively.

The Directors and senior management team will review the Company’s statement in response to any major business, organisational or legislative changes or as a result of any breach or concern regarding modern slavery.