Policy Statement

Waterscan Limited is committed to preventing all forms of modern slavery and human trafficking within our operations and supply chains and shall endeavour to uphold the principles outlined in the Modern Slavery Act 2015 and sections 15 to 25 of the Immigration, Asylum & Nationality Act 2006. We recognise that modern slavery is a violation of fundamental human rights and is inconsistent with our values and ethical principles. As such, we are dedicated to ensuring that slavery and human trafficking have no place in our business activities or our supply chains.

Policy Principles

Zero Tolerance: Waterscan maintains a zero-tolerance approach towards modern slavery and human trafficking in all aspects of our operations. We will not knowingly engage in any activities that support or perpetuate these crimes.

Legal Compliance: We are committed to complying with all relevant laws and regulations pertaining to modern slavery and human trafficking as outlined in the Modern Slavery Act 2015 and the Immigration, Asylum & Nationality Act 2006 (sections 15 to 25)

Document control: Verification documents shall comply with relevant Home Office Guidance and employees documents shall be retained securely for 2 years after any employee has left the company as mandated by law.

Supply Chain Transparency: We strive for transparency and accountability throughout our supply chains. We expect our suppliers, contractors, and business partners to adhere to ethical standards and demonstrate their commitment to combating modern slavery.

Verification: We have implemented the following measures:

• Identification of Foreign Workers: Our HR department, in collaboration with our chosen recruitment partners shall use due diligence in identifying foreign workers and record their nationalities during the initial recruitment process.
• Controls: We have controls in place to demonstrate compliance with Sections 15 to 25 of the Immigration, Asylum & Nationality Act 2006.
• Applicability to All Employees: These controls are applicable to all potential and current employees, ensuring uniformity and fairness in our hiring practices.
• Compliance with Home Office Guidance: We comply fully with the guidelines outlined in the Home Office Guidance “Full Guide for Employers on Preventing Illegal Working in the UK”

Due Diligence: We will conduct thorough due diligence to assess and help mitigate the risk of slavery and human trafficking within our business and supply chains. This includes, but is not limited to:

• Regular risk assessment via our business management system to identify and help mitigate the risk of modern slavery within both our operations and supply chains.
• Supplier questionnaires to help ensure compliance with our ethical standards.
• The engagement of external consultants working alongside HR to raise awareness and understanding of modern slavery issues.

Employee Awareness: We provide training and guidance to all relevant employees to equip them with the knowledge and tools necessary to identify and report instances of modern slavery. We encourage a culture of vigilance and responsibility across all levels of the business.

Compliance with Home Office Guidance: Waterscan Ltd. ensures that all documents used to verify employees’ right to work in the UK comply fully with the Home Office’s “Comprehensive Guidance for Employers on Preventing Illegal Working.” This commitment includes regular updates to our verification processes to align with any changes in Home Office guidance.

Document Retention Policy: Waterscan Ltd. retains copies of all right-to-work verification documents for a minimum of two years following an employee’s departure. This retention policy ensures compliance with legal obligations and allows for thorough record-keeping of all personnel’s employment eligibility.

Eligibility Assurance for Contracted Personnel: Waterscan Ltd. is committed to verifying the eligibility to work in the UK for all individuals, including agency, self-employed, and subcontracted personnel engaged in our operations. We conduct checks and require documentation from third-party agencies to confirm that all personnel meet UK right-towork requirements.

Periodic Right to Work Review: Where applicable, Waterscan Ltd. maintains a mechanism for the periodic review of right-to-work statuses for all workers, including agency, temporary, and seasonal employees. This periodic review process helps to ensure ongoing compliance with UK immigration regulations across all employment types within our organisation.

Responsibilities

Senior Management: Senior management is responsible for setting the example from the top level and ensuring that anti-slavery principles are integrated into our business practices.

Employees: All employees are expected to familiarise themselves with this policy and act in accordance with its principles. Employees are encouraged to report any concerns or suspicions of modern slavery promptly either overtly or in confidence.

Supply Chain Partners: Suppliers, contractors, and business partners are expected to comply with our Supplier Code of Conduct, which prohibits the use of forced labour, child labour, and any other forms of exploitation.

Monitoring and Review

Waterscan are committed to continuously improving our practices to combat modern slavery and uphold the rights and dignity of all individuals within our business and supply chain, therefore this policy will be reviewed annually to ensure its effectiveness and relevance. Any updates or revisions will be communicated to all relevant stakeholders.