Modern Slavery Policy

Modern Slavery and Human Trafficking Policy

1. Policy Statement

Modern slavery is a serious crime and a violation of fundamental human rights. It includes slavery, servitude, forced or compulsory labour, and human trafficking. These practices exploit individuals for personal or commercial gain and are incompatible with the values of Ligtas Consultancy and Training Ltd.

At Ligtas, we are committed to a zero-tolerance approach to modern slavery in all its forms. We conduct our business ethically and transparently, ensuring robust systems and controls are in place to prevent modern slavery within our operations and across our supply chains. This policy applies to everyone working at or with Ligtas, including employees, directors, consultants, contractors, and suppliers.

2. Purpose
The purpose of this policy is to:

• Prevent and detect modern slavery and human trafficking within our operations.
• Ensure our supply chain upholds ethical labour standards.
• Comply with the UK Modern Slavery Act 2015.
• Promote a culture of respect, dignity, and fair treatment.

3. Our Approach
Transparency and Due Diligence

We aim to be transparent in our operations and procurement processes. As part of our supplier onboarding, we carry out checks to understand the steps taken by our suppliers to prevent modern slavery. Where
relevant, we prioritise suppliers who demonstrate good practices.

Risk Assessment

We recognise that certain areas of our supply chain may present higher risks, particularly where goods and services are sourced from outside the UK or EU. We review our supply chain risks regularly.

Training and Awareness

Modern slavery awareness is part of employee induction and reinforced through ongoing learning. We ensure relevant teams are trained to identify signs of modern slavery and understand how to report concerns.

4. Responsibilities
Directors and Senior Leadership Team

Provide oversight and ensure this policy is embedded across the business.

Head of Finance: Owns day-to-day implementation, including supplier due diligence and monitoring compliance.
Line Managers: Ensure their teams understand this policy and receive appropriate training.
All Staff: Expected to read, understand, and act in accordance with this policy. Everyone plays a part in identifying and reporting concerns.

5. Reporting Concerns

If you suspect modern slavery or human trafficking is taking place:

Raise your concern immediately with your line manager or the Head of Finance.

Alternatively, contact: HR or a Director directly

Reports can be made anonymously.

We will support anyone who raises concerns in good faith.

Ligtas is committed to protecting whistleblowers from retaliation. We encourage openness and will not
tolerate any victimisation resulting from a report made in line with this policy.

6. Breaches of the Policy

Any breach of this policy by an employee will result in disciplinary action, which may include dismissal for gross misconduct.
Suppliers or contractors who fail to comply with this policy will be subject to review and may have their contracts terminated.

7. Monitoring and Review

This policy will be reviewed annually or sooner if legislation or company operations change. Performance is monitored through internal audits, supplier reviews, and feedback channels.

8. Communication

This policy is:

Shared internally via the Ligtas Intranet.

Available to all external stakeholders upon request.

Communicated to new and existing suppliers and partners as part of our onboarding and ongoing
relationships.