Modern Slavery Statement

At Red The Consultancy Europe Limited we believe in the importance of equality in the workplace. Being a responsible corporate citizen is not only the right thing to do, it is good for the long-term viability of our business. We have an established Employee Code of Conduct which details the standards by which we operate. We expect these same high standards from our suppliers. We are committed to preventing acts of modern slavery and human trafficking from occurring within our business and the supply chain.

We are developing a Red The Consultancy Europe Limited Supplier Code of Conduct which makes it clear that we expect the staff employed by our suppliers, whether permanent or temporary, to have the same basic right to be treated with respect and dignity at work as our own employees. We believe employment should be chosen. There must be no forced, bonded or involuntary prison labour. Supplier employees must not be required to lodge monies or identity papers in order to work and must be free to leave employment after the giving of reasonable notice.

Our UK Supply Chain

As a provider of recruitment services we do not have a particularly long or complex supply chain. In the UK we work with a small range of suppliers who provide goods and services across a number of different categories, predominantly Marine/Shipping, Financial Services and Renewable Energy. Therefore, we have close relationships with our suppliers and good visibility of our supply chain, and do not feel that it is particularly susceptible to labour exploitation or other forms of slavery and human trafficking. Nevertheless, we are committed to preventing these practices from occurring within both our business and our supply chain, which is demonstrated by our policies and due diligence procedures as outlined below.

Our Policy on Modern Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in our business.

Due Diligence Processes for Slavery and Human Trafficking

Our Own Business

As part of our own business we supply temporary personnel to a number of clients. In this respect we have established and audited procedures to ensure that those employees:-

• have a right to work in the UK. This involves asking the individual direct to view their passport. A delay in providing the passport might indicate a modern slavery issue; where we provide payroll services as required by our own clients, we check that such temporary personnel have a bank account in their own name into which their remuneration is paid; and where we are responsible for such temporary personnel whilst they are employed on our client’s premises, they are free to leave their assignment on reasonable notice.

In addition, our employees, through the Employee Code of Conduct, are made aware of Red The Consultancy Europe Limited’s requirement for employees to support and uphold human rights principles and know that Red The Consultancy Europe Limited will not tolerate, engage in or support the use of, forced labour.

Our Supply Chain

As part of our initiative to identify, monitor and reduce the risk of slavery and human trafficking occurring within our supply chain, we have undertaken the following due diligence procedures:-

(a) we have commenced the mapping of suppliers who provide goods and services to our UK business to identify those suppliers whose goods or services are heavily dependent on the provision of people;

(b) we have started to assess those suppliers in the UK supply chain who we believe are in a high risk area, and will write to each such supplier to note our commitment to transparency and combatting modern slavery within our own organisation and our similar expectation from suppliers of goods and services to us.

We will include appropriate terms in our agreements which place an obligation on suppliers to comply with the Modern Slavery Act 2015. If we were to find evidence that one of our suppliers has failed to comply with the Modern Slavery Act 2015 then we would require the relevant supplier to remedy such non-compliance and we would consider terminating our relationship should we see no improvement in the way their business is conducted.

This approach is designed to:

• identify and assess potential risk areas in our UK supply chain;

• mitigate the risk of slavery and human trafficking occurring in the supply chain;

• monitor potential risk areas in the supply chain; and

• provide adequate protection to whistle blowers.

Risk and Compliance

Red The Consultancy Europe Limited has evaluated the nature and extent of its exposure to the risk of modern slavery occurring in its UK supply chain. As our core business is focused on the provision of recruitment services in respect of professionals, office and administrative workers (rather than in relation to agriculture, retail or manufacturing, which are sectors we perceive to present a higher risk of labour exploitation and modern slavery), we do not consider that we operate in a particularly high risk sector. This evaluation process will continue on an annual basis.

Training and Performance Indicators

Given our view that Red The Consultancy Europe Limited's exposure to modern slavery risk is limited, and the existing due diligence processes we already have in place as an

organisation, we have not implemented any specific training or key performance indicators in relation to modern slavery and human trafficking during the previous financial year.

Further Steps

Following a review of the effectiveness of the steps we have taken so far this financial year to prevent modern slavery or human trafficking occurring in our business and UK supply chain we intend to take the following further steps to combat slavery and human trafficking during the course of the 2020 financial year:

• to complete the mapping of our UK suppliers;

• include appropriate anti-modern slavery terms in our agreements with suppliers;

• continuing to raise awareness with our key teams provided through training to ensure a high level of understanding of the risks of modern slavery and so they are aware of what to look out for in respect of modern slavery; and

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending 31st May 2023.


Matthew Welstead

Managing Director

Red The Consultancy Europe Limited