Modern Slavery Statement

ORGANISATION

This statement applies to all companies within and associated to Aspion (referred to in this statement as ‘The Group’).

DEFINITIONS
The group considers that modern slavery encompasses:

• Human trafficking;
• Forced work, through mental or physical threat;
• Being owned or controlled by an employer through mental or physical abuse of the threat of abuse;
• Being dehumanised, treated as a commodity or being bought or sold as property;
• Being physically constrained or to have restriction placed on freedom of movement.

COMMITMENT
The group acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The group understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The group does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to the group in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The group strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom.

POTENTIAL EXPOSURE
The Group considers its exposure to slavery/human trafficking to be extremely low, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

STEPS
The group carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

The group has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the group has taken the following steps to ensure that modern slavery is not taking place:

• reviewing supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery;
• measures in place to identify and assess the potential risks in its supply chains;
• undertaking impact assessments of its services upon potential instances of slavery;
• created action plans to address risk to modern slavery;
• actions taken to embed a zero-tolerance policy towards modern slavery;

KEY PERFORMANCE INDICATORS
The group has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the group or its supply chains.

Tier 1, 2 and 3 suppliers assessed for modern slavery risk;
Tier 1, 2 and 3 suppliers subject to enhanced risk assessment;

TRAINING
The Group provides the following training to staff to effectively implement its stance on modern slavery Induction training & training on modern slavery policies.

K) SLAVERY COMPLIANCE OFFICER
The group has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Operations Director obligations in this regard.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.