HIVE PFP Limited Modern Slavery Policy

Modern slavery is an umbrella term that encompasses a wide spectrum of crime, including human trafficking, slavery, servitude, and forced labour. The term refers to situations of exploitation that a person cannot leave due to coercion, use of force, abuse of vulnerability, deception or other means. It is the illegal exploitation of people for personal or commercial gain and is a violation of fundamental human rights. Unscrupulous businesses who use slave labour undercut businesses and if this horrendous crime is to be eradicated from the UK and the rest of the world, government and businesses must work together.

At HIVE PFP Limited, we have adopted a proactive approach to mitigating modern slavery and all forms of corruption and bribery, directly and indirectly, associated with these criminal acts. While no such abuse is tolerated, an open and transparent approach is required by all businesses, organisations, and governmental bodies to ensure steps are taken to identify and tackle any instances of modern slavery in the workforce and supply chains.

Modern slavery is so pervasive that it is likely to exist in the supply chains of the goods and services purchased by public bodies. HIVE PFP Limited is committed to ensuring that our operations do not inadvertently fund this criminal activity and is committed to protecting employees, clients, and in its own supply chains from exploitation or harm. Hive PFP Limited fully supports the government’s objectives to eradicate modern slavery and human trafficking, and believes that everyone has a right to be treated with dignity and respect at all times and under all circumstances.

Definitions

• Modern slavery is the term used within the UK to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking and the associated criminal offences are defined within the Modern Slavery Act 2015 (the ‘Act’).

• Human trafficking is where a person arranges, or facilitates, the travel of another person with a view to that person being exploited.

Policy Aims

This policy provides a framework to ensure:

• All employees and board members understand and are aware of their responsibilities in relation to modern slavery.

• The development of a strategic approach to identifying and tackling any modern slavery within Hive PFP Limiteds supply chains aligning with the requirements of the Procurement Act 2023 and relevant government guidance.

• The implementation of robust, transparent and proportionate governance and assurance processes.

• Reporting instances (or concerns) of modern slavery.

Responsibilities and Accountabilities

HIVE PFP Limited recognises that it is responsible for promoting ethical business practices and policies that protect workers from being abused or exploited. The prevention, detection and reporting of modern slavery in any business or its supply chain is the responsibility of all those working for us or on our behalf. Any passholder must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy. Therefore, this policy applies to all persons working for, or on behalf of HIVE PFP Limited, in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents and contractors.

The HIVE PFP Limited Executive Board have overall responsibility for ensuring this policy complies with legal and ethical obligations, and that all those under our control comply with it. Contractor Responsibilities.

HIVE PFP Limited requires all organisations and contractors with whom it is engaged to:

• Fully comply with the Act.

• Operate their business and manage their supply chains in a clear, transparent, accountable and auditable manner.

• Undertake modern slavery risk assessments, both at contract inception and throughout the contract lifecycle, as and when required, using risk indicators aligned with government guidance.

• Be free from ethical ambiguities.

HIVE PFP Limited expects that its contractors operate to the highest level of ethical standards and will hold their own suppliers to the same high standards. All contractors must pay their dedicated staff working in London at least the London Living Wage, or the UK Living Wage for dedicated staff working outside London. Contractors who supply goods or services deemed to be at particular risk of modern slavery may be required to provide additional confirmation and evidence that their practices conform with all relevant policies and legal requirements relating to modern slavery. These steps are to allow HIVE PFP Limited to reduce the risks of modern slavery and work in partnership with contractors that proactively attempt to reduce the risk of exploitation of workers in their supply chains.

Awareness and Training

HIVE PFP Limited will raise awareness of this policy (and the Act) by notifying staff members internally via this policy and the company handbook. Any contractors, suppliers, and other organisations with which we regularly engage will also be made aware of this policy, and are also required to provide their own Modern Slavery Policy during the onboarding process.

This policy will be published internally on the company drive, referenced within the company handbook. This policy will also be provided upon request to clients, contractors, suppliers, and other organisations with which we regularly engage.

Appropriate training and guidance will be provided for all HIVE PFP Limited staff to include identifying the risks of modern slavery and ensure that suspected instances are handled correctly as part of mandatory CPD requirements, and will maintain records of all staff members that have completed this training as part of the standard CPD recording process.

Assurance and Transparency

HIVE PFP Limited has committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within the business or it’s supply chains. To supplement this policy, HIVE PFP Limited will voluntarily publish this policy on the company website.

Where high-risk supply chains are identified (e.g., construction, electronics, apparel, catering), HIVE PFP Limited may require additional due diligence, including audit evidence, or independent third-party assurance.

Non-Compliance, Reporting and Victim Support

If any member of HIVE PFP Limited is discovered to have breached this policy, then appropriate action will be taken. If any contractor is found to have breached this policy, then appropriate action will be taken; this may range from considering the possibility of breaches being remediated, to terminating agreements. Individuals who have reasonable suspicion or evidence of modern slavery or noncompliance with the Act must immediately report their concerns to their line manager or HR. If the incident has a high level of threat or risk of harm, individuals must always refer the case to the emergency services on 999 as a first port of call. Children should always be referred into the authorities immediately.

HIVE PFP Limited will take a victim-centred approach in order to protect any victims of modern slavery from further harm or vulnerability. We will always act on a case-by-case basis, considering individual circumstances. We aim to follow a collaborative approach with our supply chain, only terminating contracts as a last course of action. We commit to working with partners through a multi-stakeholder approach, taking into consideration continuous learning and adapting our practices based on best practice and our experiences. We require suppliers to act in accordance with these principles where supply chain incidents require remediation.

If you would like to raise a concern about a suspicion you have outside of work (at home or in your community):

• Contact the UK Modern Slavery Helpline on 080 0012 1700 or report it online.

• Contact the Victim Support Helpline on 080 8168 9111 or visit the Victim Support website.

Policy Review

This policy, along with all HIVE PFP Limited policies will be reviewed periodically, to establish whether the approaches continue to follow best practice, and will consider government updates, modern slavery guidance, and evolving best practice on ethical procurement and human rights due diligence.

For more information on modern slavery, the latest updates can be found at: https://www.gov.uk/government/collections/modern-slavery

Modern Slavery Act 2015 can be found at: https://www.legislation.gov.uk/ukpga/2015/30/contents