Modern Slavery and Human Trafficking Policy

1. Policy Statement

Tilo Consulting Limited is committed to preventing modern slavery and human trafficking in all its business activities and supply chains. 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 involve the deprivation of a person's liberty by another to exploit them for personal or commercial gain.

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

2. About This Policy

The purpose of this policy is to:

• Set out our responsibilities, and those working for and on our behalf, in observing and upholding our position on modern slavery and human trafficking.
• Provide information to those working for and on our behalf on how to identify and report concerns regarding modern slavery and human trafficking.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

3. Responsibility for the Policy

The board of directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The Risk and Compliance Director (RCD) has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

4. Compliance with the Policy

All employees and those working for or on behalf of Tilo Consulting Limited must:

• Read, understand, and comply with this policy.
• Avoid any activity that might lead to, or suggest, a breach of this policy.
• Report any concerns about modern slavery or human trafficking in any part of our business or supply chains at the earliest possible stage.

5. Reporting Concerns

Employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains. If you believe or suspect that a breach of this policy has occurred or that it may occur, you must notify your manager or the Risk and Compliance Director or report it in accordance with our Whistleblowing Policy as soon as possible.

6. Training and Awareness

We will provide training to all employees to ensure a high level of understanding of the risks of modern slavery and human trafficking in our business and supply chains. This training will be part of the induction process for all new employees and will be regularly updated.

7. Monitoring and Review

The Risk and Compliance Director will monitor the effectiveness and review the implementation of this policy, considering its suitability, adequacy, and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to ensure they are effective in countering modern slavery.