Modern Slavery Policy

Purpose

This policy sets out The Cinch Group’s commitment to preventing modern slavery and human trafficking in our operations and supply chains. It explains the steps we take to identify, prevent and address modern slavery risks and the responsibilities of our people and partners in upholding these standards.

Scope

This policy applies to all employees, contractors, temporary workers, officers and directors of The Cinch Group and to all suppliers, subcontractors and business partners who provide goods or services to us in the UK and internationally.

Definitions

Modern slavery includes slavery, servitude, forced or compulsory labour and human trafficking. Supplier means any third-party providing goods or services to The Cinch Group, including subcontractors and labour providers.

Policy Statement

The Cinch Group has a zero-tolerance approach to modern slavery. We are committed to acting ethically, transparently and with integrity in all business dealings and to implementing and enforcing effective systems and controls to safeguard against modern slavery occurring in our business or supply chains. This statement is made pursuant to section 54 of the Modern Slavery Act 2015.

Responsibilities

  • Board of Directors: Provide oversight, approve this policy and ensure adequate resources for implementation and monitoring.
  • Senior Management: Ensure the policy is implemented across their areas, that risk assessments are completed and that corrective actions are taken where necessary.
  • HR and Compliance Teams: Maintain recruitment checks, deliver training, manage whistleblowing channels and conduct supplier due diligence.
  • All Employees and Contractors: Comply with this policy, complete required training and report any concerns promptly.

Due Diligence and Risk Assessment

  • We conduct risk-based due diligence on suppliers before onboarding and periodically thereafter. Due diligence includes identity and ownership checks, review of public records and media searches, and assessment of labour practices.
  • We maintain an approved supplier list and require suppliers to complete pre-contract checks and declarations regarding modern slavery and labour standards.
  • Where higher risk is identified, we require enhanced due diligence, contractual safeguards and, where appropriate, on-site or third-party audits.

Supplier Requirements and Contractual Controls

  • Suppliers must confirm they have taken steps to eradicate modern slavery within their business and that they hold their own suppliers to account.
  • Suppliers must confirm compliance with applicable wage laws, including payment of at least the national minimum wage or national living wage as appropriate.
  • Our standard supplier contracts include anti-slavery clauses requiring compliance with this policy and the right to terminate the contract if modern slavery is discovered.
  • We reserve the right to suspend or terminate relationships with suppliers who fail to meet our standards or who do not remediate identified issues within an agreed timeframe.

Recruitment and Employment Practices

  • We operate robust recruitment and right-to-work checks for all employees and workers to prevent forced labour and human trafficking.
  • We do not retain original identity documents as a condition of employment, and we ensure workers are free to leave employment after reasonable notice.
  • We prohibit the use of child labour and compulsory labour in our operations and expect the same from our suppliers.

Training and Awareness

  • We provide regular training to employees and managers on recognising the signs of modern slavery, reporting procedures and the requirements of this policy.
  • Targeted training is provided to teams involved in procurement, recruitment and supplier management.

Reporting, Whistleblowing and Remediation

  • We encourage all employees, contractors and third parties to report concerns about modern slavery. Reports can be made confidentially to line managers, HR or via our whistleblowing channel at hello@thecinchgroup.com
  • We will investigate all reports promptly and fairly. Where modern slavery is suspected or confirmed, we will take appropriate remedial action, which may include terminating supplier relationships, support affected individuals and cooperating with law enforcement.
  • We will protect anyone who raises concerns in good faith from retaliation.

Monitoring, Audit and Review

  • We monitor supplier compliance through regular communication, periodic reviews and risk-based audits. We review recruitment and payroll processes to ensure they remain free from coercion or exploitation.
  • This policy and our modern slavery statement will be reviewed at least annually and updated as necessary to reflect changes in law, guidance and our business operations.

Governance and Approval

This policy is approved by the Board of Directors and is owned by the Head of Compliance. Non-compliance with this policy may result in disciplinary action up to and including termination of employment and termination of supplier contracts.

Approved by: Kam Jittlar, Managing Director

Date of approval: 1st April 2025

Contact

For questions about this policy or to report concerns, contact hello@thecinchgroup.com or your line manager.

Commitment The Cinch Group is committed to continuous improvement in preventing modern slavery and will work with suppliers, partners and stakeholders to raise standards across the supply chain.