Anti-Slavery and Human Trafficking Policy

1. Introduction

Maxwell Stephens Limited is committed to conducting its business ethically, responsibly and with integrity.

This policy sets out the steps we take to identify, assess and address the risk of modern slavery and human trafficking within our own operations and throughout our supply chains. We recognise our responsibility to maintain a robust and proportionate approach to preventing exploitation in every area of our business.

Maxwell Stephens has a zero-tolerance approach to modern slavery, forced labour, servitude, child labour and human trafficking. We are committed to ensuring that these practices have no place within our organisation or within the businesses and suppliers with which we work.

2. Purpose of This Policy

The purpose of this policy is to:

• Communicate Maxwell Stephens’ commitment to preventing modern slavery and human trafficking.
• Establish the standards expected from employees, workers, suppliers, contractors and business partners.
• Support the identification, prevention and reporting of potential modern slavery risks.
• Promote responsible and ethical practices across our operations and supply chains.
• Provide a framework for responding appropriately where concerns or breaches are identified.

3. Scope

This policy applies to everyone working for Maxwell Stephens or acting on our behalf, including:

• Directors and employees.
• Temporary and agency workers.
• Consultants and contractors.
• Suppliers and subcontractors.
• Business partners and other third parties providing goods or services to the company.

We expect all individuals and organisations within the scope of this policy to support and uphold its principles.

4. Our Commitments

Maxwell Stephens is committed to the following measures:

Zero Tolerance

We maintain a zero-tolerance approach to all forms of modern slavery and human trafficking within our organisation and supply chains.

Shared Responsibility

Preventing, identifying and reporting modern slavery is the responsibility of everyone working for us or on our behalf.

No employee, worker, supplier or business partner may engage in, facilitate, conceal or fail to report any activity that could result in, contribute to or suggest a breach of this policy.

Stakeholder and Supplier Engagement

We are committed to working constructively with suppliers, contractors and other stakeholders to identify and address modern slavery risks within our operations and supply chains.

Risk-Based Contracting

We take a proportionate, risk-based approach to our procurement and contracting arrangements and keep these processes under review.

Where appropriate, we may:

• Include contractual provisions prohibiting modern slavery, forced labour and human trafficking.
• Require suppliers and other third parties to comply with our standards or Code of Conduct.
• Request information about the policies, procedures and controls used by suppliers to manage modern slavery risks.
• Consider modern slavery compliance when selecting, reviewing or renewing supplier relationships.

Due Diligence and Monitoring

As part of our ongoing risk assessment and due diligence processes, we will consider whether additional checks or monitoring are appropriate.

Depending on the level of risk identified, this may include:

• Requesting further information from suppliers.
• Reviewing supplier policies and working practices.
• Seeking evidence of compliance.
• Requiring corrective action plans.
• Conducting or commissioning audits where proportionate.

Appropriate Action

Where an individual or organisation working for us or on our behalf is found to have breached this policy, Maxwell Stephens will take appropriate action.

The action taken will depend on the nature and seriousness of the breach and may include:

• Investigating the circumstances fully.
• Requiring immediate corrective or remedial action.
• Supporting remediation where this provides the best outcome for affected individuals.
• Suspending or terminating a contract, appointment or business relationship.
• Reporting the matter to the appropriate authorities where necessary.

Our response will prioritise the safety, welfare and rights of any individual affected by exploitation.

5. Reporting Concerns

Anyone who becomes aware of, or suspects, modern slavery or human trafficking within Maxwell Stephens’ operations or supply chains must report the concern promptly.

Concerns should be raised with an appropriate manager or senior representative of Maxwell Stephens. Reports will be treated seriously, sensitively and, wherever possible, confidentially.

No individual should suffer detrimental treatment for raising a genuine concern in good faith.

6. Training and Awareness

Maxwell Stephens will promote awareness of modern slavery risks and the responsibilities set out in this policy.

Where appropriate, employees and other relevant individuals may receive guidance or training to help them:

• Recognise potential indicators of exploitation.
• Understand how modern slavery risks may arise.
• Know how and where to report concerns.
• Apply appropriate due diligence when working with suppliers and third parties.

7. Governance and Review

Responsibility for overseeing this policy rests with the senior leadership of Maxwell Stephens Limited.

This policy will be reviewed periodically and updated where necessary to reflect changes in:

• Legislation and regulatory guidance.
• Business operations.
• Supply-chain risks.
• Industry standards and recognised best practice.

Maxwell Stephens remains committed to continually improving its approach to preventing modern slavery and human trafficking.

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