Modern Slavery Policy

Zenzero Solutions Ltd

Policy owner: Head of Quality and Compliance

Approved by: Chief Executive

Next review due: September 2027

Zenzero Solutions Ltd is committed to ensuring that there is no modern slavery or human trafficking in any part of our business, and to requiring our suppliers to hold a similar ethos. This policy sets out how we identify, prevent and respond to the risk of modern slavery in our own operations and in our supply chain, and how we protect anyone who brings a concern to us.

1.0 Policy statement

1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour, debt bondage, child labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

1.2 We have a zero tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in our own business or in any of our supply chains.

1.3 We are also committed to ensuring that there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with the disclosure obligations under the Modern Slavery Act 2015.

1.4 We expect the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting processes we include specific prohibitions against the use of forced, compulsory or trafficked labour, or of anyone held in slavery or servitude, whether adults or children, and we expect our suppliers to hold their own suppliers to the same standards.

1.5 We recognise that finding no cases is not the same as having no risk. The Home Office statutory guidance is explicit that an organisation which identifies no risks or incidents may simply not be looking hard enough, and we approach our own assurance work on that basis.

2.0 Scope

2.1 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third party representatives and business partners.

2.2 It applies to all of our operations and to every tier of our supply chain, including indirect suppliers and subcontractors engaged by the suppliers we contract with directly.

2.3 This policy does not form part of any employee’s contract of employment, and we may amend it at any time.

3.0 What modern slavery means

3.1 In this policy, modern slavery means a situation of exploitation that a person cannot refuse or leave, because they are subject to threats, violence, coercion, deception or an abuse of power.

3.2 The Modern Slavery Act 2015 creates the offences of slavery, servitude and forced or compulsory labour, and of human trafficking. The practices most often seen in a business context include forced labour, debt bondage, the withholding of identity documents, unlawful deductions from wages, recruitment fees charged to workers, restrictions on freedom of movement and child labour.

3.3 Forced labour is the most common form of modern slavery. The International Labour Organization defines it as work or service exacted from a person under the threat of a penalty, and for which that person has not offered themselves voluntarily.

4.0 Legal and regulatory framework

4.1 This policy is written to meet our obligations under, and our commitments to, the following:

· the Modern Slavery Act 2015, including the offences at sections 1 and 2 and the transparency in supply chains duty at section 54

· the Home Office statutory guidance, Transparency in Supply Chains: A Practical Guide, as updated in 2025

· the Employment Rights Act 1996, as amended by the Public Interest Disclosure Act 1998, which protects workers who make a qualifying disclosure

· the Immigration, Asylum and Nationality Act 2006, which governs right to work checks

· the Employment Agencies Act 1973 and the Gangmasters (Licensing) Act 2004, which govern labour providers

· the UN Guiding Principles on Business and Human Rights, and the core conventions of the International Labour Organization

4.2 Section 54 of the Act requires a commercial organisation carrying on business in the UK, supplying goods or services, with a total annual turnover of 36 million pounds or more, to publish a slavery and human trafficking statement for each financial year. That statement must be approved by the board, signed by a director, and published on the organisation’s website

with a link from the homepage. The government also expects it to be uploaded to the modern slavery statement registry.

4.3 Zenzero meets that threshold and is within the scope of section 54. We publish a slavery and human trafficking statement for each financial year, within six months of the financial year end, and we report against the six areas set out in the statutory guidance: organisational structure and supply chains, policies, due diligence, assessing and managing risk, monitoring and effectiveness, and training.

4.4 The 2025 guidance sets out two tiers of disclosure. Level 1 is the baseline expected of every reporting organisation. Level 2 is the fuller disclosure expected as an organisation matures. Our intention is to meet Level 1 across all six areas and to move progressively towards Level 2, and we assess ourselves against that benchmark each year.

5.0 Responsibility for the policy

5.1 The Chief Executive of Zenzero Solutions Ltd has overall responsibility for ensuring that this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

5.2 The Head of Quality and Compliance owns this policy. That role maintains the modern slavery risk assessment and the supporting due diligence records, receives and handles concerns raised under this policy, and reports on both to the Chief Executive.

5.3 Business managers have primary and day to day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure that they are effective in countering modern slavery.

5.4 Management at all levels are responsible for ensuring that those reporting to them understand and comply with this policy, and are given adequate and regular training on it and on the issue of modern slavery in supply chains.

5.5 The Head of Quality and Compliance prepares the annual slavery and human trafficking statement required by section 54. The statement is put to the board for approval and signed by a director before it is published on our website, with a link from the homepage, and uploaded to the government’s modern slavery statement registry.

6.0 Assessing and managing risk

6.1 We assess modern slavery risk across both our own operations and our supply chain. The assessment is refreshed at least annually, and sooner if there is a significant change to our supplier base, to the services we deliver, or to our own working arrangements.

6.2 The assessment considers sector, geography, workforce profile and the nature of the goods or services being supplied. We pay particular attention to:

· labour supplied to us or to our suppliers through agencies, subcontractors or other labour providers

· services where low paid, temporary or migrant labour is common, such as cleaning, security, catering, logistics, waste and facilities work

· hardware, components and consumables manufactured, assembled or refurbished in higher risk countries

· suppliers who rely on recruitment intermediaries, particularly where workers move across borders to take up the work

· any part of the supply chain where our visibility does not extend below the first tier

6.3 We record the limits of what we know, including where our supply chain mapping stops, and we set out what we plan to do to improve that visibility. Risk is prioritised by the severity of the potential harm to workers and by the leverage we realistically hold with the supplier concerned, rather than by the commercial value of the contract.

6.4 Modern slavery risk is treated as part of our wider compliance and supplier risk framework rather than as a separate exercise, so that it is considered at the same points as information security, data protection and financial due diligence.

7.0 Due diligence in our supply chain

Onboarding a new supplier

7.1 New suppliers are screened before we place a first order. Screening covers their legal status and ownership, their own modern slavery policy or published statement where one is required of them, their recruitment and labour practices, and the approach they take to their own suppliers.

7.2 Our contracts include a prohibition on the use of forced, compulsory or trafficked labour, a requirement to cascade equivalent terms to subcontractors, a duty to notify us of any suspected case, a right for us to request information, and, for higher risk suppliers, a right to audit.

Managing suppliers on an ongoing basis

7.3 Higher risk suppliers are reassessed periodically. Depending on the risk we may ask for audit reports, the findings of worker interviews, pay and hours records, or evidence of certification. Desk based assurance alone is not treated as sufficient for a supplier we have identified as higher risk.

7.4 Where we find a problem we prefer engagement and a corrective action plan to immediate termination. Exiting a supplier abruptly can leave the affected workers without income and without remedy, which is the opposite of what this policy is for. Termination is the right answer where a supplier will not engage, or where the harm cannot be put right.

7.5 We adopt responsible purchasing practices. Unrealistic pricing, compressed lead times and late changes to volume push suppliers towards unlawful labour practices, so we take our own buying behaviour into account when we negotiate and when we place work at short notice.