OVERVIEW AND HOW WE DEFINE MODERN SLAVERY

1.1 Slavery, child labour and human trafficking are serious crimes and a violation of fundamental human rights. There are various forms of this ‘Modern Slavery’, as defined under UK Modern Slavery Act 2015 (the “UK Act”) and the Australian Modern Slavery Act 2018 (Cth) (the “Australian Act”), which deprives victims of their liberty and usually involves financial exploitation.

1.2 At Ademco Security Group (the Company), we conduct our business fairly, ethically and with respect to fundamental human rights. We are fully committed to the prevention of all forms of slavery, forced labour or servitude, child labour and human trafficking, both in our business and in our supply chains.

1.3 The Company’s Anti-Slavery Officer XXXX (‘ASO’) is responsible for this policy.

1.4 You are required to read and comply with this policy if you work for, or on behalf of the Company in any capacity including as: an employee, director, officer, worker, consultant, volunteer, supplier or service provider.

1.6 Failure to comply with this policy may result in disciplinary action, including dismissal, or termination of the contract between you and the Company. It could also involve other legal steps being taken against you.

PREVENTING SLAVERY AND HUMAN-TRAFFICKING IN OUR BUSINESS

2.1 The Company operates robust recruitment processes in line with the respective countries’ employment law including document checks to ensure that all employees have the right to work in the respective country.

2.2 The Company provides every employee with a written contract of employment. We pay every employee in accordance with the law. We comply with our legal obligations to ensure the health and safety of all of our employees and workers, including in relation to working hours, rest breaks and holidays.

2.3 We operate a responsible purchasing policy which reflects our commitment to and focus on suppliers’ ethical supply chains. We make appropriate checks on all recruitment agencies and suppliers.

2.4 All employees are required to sign a copy of this policy to show they have read and understood it. All managers are provided with training on this policy.

2.5 We have practices in place to ensure all our employees recognise different types of slavery as defined under the UK Act and the Australian Act, how to spot the signs of slavery and how to report any concerns.

IF YOU ARE ONE OF OUR SUPPLIERS

3.1 If you supply the Company with goods or services, you must assess your business and supply chains and confirm to our ASO that you comply with your legal obligations, in relation to the UK Act and the Australian Act, and are committed to ensuring there is no slavery, forced labour or servitude, child labour or human trafficking taking place in your business, or any of your supply chains. You must also provide a copy of your anti-slavery policy.

3.2 If you breach this policy, or are found to have slavery or human trafficking in your business, or knowingly in your supply chain, the Company may terminate the contract with you and pursue its legal remedies against you.

IF YOU ARE AN EMPLOYEE OR WORKER PROVIDING SERVICES FOR US

4.1 You must immediately report any suspicions of Modern Slavery or human trafficking in our business or supply chains to our ASO. Our ASO will investigate and report to our Board of Directors, within a reasonable time, on actions which may require to be taken.

4.2 You will not suffer any detrimental treatment as a result of reporting any genuine concerns, raised in good faith, under this policy. This applies, even if after investigation, they are found to be mistaken. If you believe that you have suffered any such treatment, you should immediately inform our ASO and if you are an employee, refer to our Grievance and Whistleblowing Policies.