This policy communicates the reasons for having an anti-slavery policy and our standards in which we operate to ensure this policy is adhered to. We have a zero tolerance approach to slavery and we are committed to preventing acts of slavery or trafficking from occurring within our business and would look to expect these same standards reflected in our users, contractors, suppliers, and other business partners.

Modern slavery is a criminal offence under the Modern Slavery Act 2015 (the “Act”). Modern slavery can occur in various forms, including servitude, forced or 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. This document sets out the policy of Sofia Gray and its associated companies with the aim of preventing opportunities for modern slavery to occur within its businesses or supply chain. This policy’s use of the term “modern slavery” has the meaning given in the Act.

As a Group, we have a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own businesses or those of our suppliers.

We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and we are evolving and updating our contracting processes to 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 our suppliers to hold their own suppliers to the same high standards.

All users and team members have an obligation to familiarise themselves with our procedures to help in the identification and prevention of modern slavery and to conduct business in a manner such that the opportunity for and incidence of modern slavery is prevented.

To underpin our compliance with the Modern Slavery Act 2015, we have implemented the following measures:

• conduct risk assessments to determine which parts of our business and which of our suppliers are most at risk of modern slavery so that efforts can be focused on those areas
• engage with our suppliers both to convey to them our Anti-Slavery Policy and to gain an understanding of the measures taken by them to ensure modern slavery is not occurring in their businesses
• Ongoing assessment of our user base to evaluate potential instances of modern slavery

Responsibility for the prevention of modern slavery rests with the Company’s leadership.

Team members at all levels are responsible for ensuring they understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery.