Modern Slavery Statement

39D Services Limited (“39D”) is committed to combating all forms of modern slavery and human trafficking. This policy statement outlines our approach to ensuring that modern slavery is not taking place anywhere within our own business or in any of our supply chains. We acknowledge our responsibility under the Modern Slavery Act 2015 and strive to act ethically and with integrity in all our business dealings.

Our Commitment

39D is dedicated to ensuring there is no modern slavery or human trafficking in our supply chains or in any part of our business. We operate a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business relationships. We implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our supply chains.

Our Policies

To underpin our commitment to combatting modern slavery, we have implemented the following policies:

1. Ethical Trading Policy: Outlines our commitment to ethical business practices, including the prohibition of forced, bonded, or compulsory labour.
2. Supplier Code of Conduct: Requires all our suppliers to comply with all local laws and regulations, including those related to labour practices and modern slavery.
3. Whistleblowing Policy: Encourages and enables employees and others to raise serious concerns, including those related to modern slavery, within the company without fear of reprisal.

Due Diligence Processes

As part of our initiative to identify and mitigate the risks of modern slavery, we:

• Conduct risk assessments to determine which parts of our business and supply chains are most at risk from modern slavery.
• Engage with suppliers to ensure they are aware of our policies and expectations regarding modern slavery.
• Include modern slavery considerations in our supplier selection and evaluation processes.
• Conduct audits and assessments of suppliers where deemed necessary.

Training and Awareness

We provide training to our employees to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business. This includes:

• Annual training sessions for key staff members involved in procurement and supply chain management.
• Awareness campaigns to highlight the issue of modern slavery and the ways it can be identified and reported.

Reporting Concerns

We encourage all employees, suppliers, and other business partners to report any concerns related to modern slavery. Reports can be made confidentially via our whistleblowing hotline or directly to the management team.

Continuous Improvement

We are committed to continually improving our practices to combat modern slavery. This includes:

• Regularly reviewing and updating our policies and procedures.
• Engaging with stakeholders to identify and address any areas for improvement.
• Monitoring and reporting on our progress in addressing modern slavery risks.

Approval

This policy statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 and constitutes 39D’s modern slavery and human trafficking statement for the financial year ending 2023.

This statement has been approved by the board of directors of 39D Services Limited.

Matthew Southgate
Director