ASTON BUILDING SUPPLIES LTD

MODERN SLAVERY AND HUMAN TRAFFICKING POLICY

Company: Aston Building Supplies Ltd
Policy: Modern Slavery and Human Trafficking Policy
Effective Date: 24 September 2026
Review Date: 24 September 2027

1. Policy Statement

Aston Building Supplies Ltd is committed to conducting its business ethically, responsibly and with respect for human rights.

We have a zero-tolerance approach to modern slavery, human trafficking, forced labour, servitude and child labour within our business operations and supply chain.

We are committed to taking reasonable and proportionate steps to identify, prevent and address the risk of modern slavery and human trafficking in our business and supply chain.

This policy applies to Aston Building Supplies Ltd, its employees, directors, contractors, suppliers and other business partners where relevant.

2. Our Commitment

Aston Building Supplies Ltd will:

• Not knowingly support or engage with any form of forced or involuntary labour.
• Not tolerate slavery, human trafficking, servitude or exploitation of workers.
• Not knowingly employ anyone under conditions that breach applicable UK employment laws.
• Expect our suppliers and business partners to operate in accordance with applicable laws relating to modern slavery and human rights.
• Take reasonable steps to assess modern slavery risks within our supply chain.
• Raise concerns where potential exploitation or unethical employment practices are identified.
• Take appropriate action where concerns are substantiated.

3. Supply Chain

Aston Building Supplies Ltd sources products and materials from suppliers in the UK and overseas.

We recognise that risks relating to modern slavery may exist within international manufacturing, logistics and other parts of the supply chain.

Where appropriate, we will:

• Conduct reasonable due diligence on new suppliers and business partners.
• Request relevant information regarding labour and employment practices where appropriate.
• Expect suppliers to comply with applicable employment, human rights and anti-slavery legislation.
• Consider modern slavery risks when selecting and reviewing suppliers.
• Review concerns or allegations relating to forced labour or human trafficking.
• Take appropriate action where a supplier fails to meet our expectations or applicable legal requirements.

4. Employees and Recruitment

Aston Building Supplies Ltd is committed to fair and lawful employment practices.

We will ensure that:

• Employees are employed voluntarily and are free to leave employment in accordance with their contractual and legal rights.
• Appropriate right-to-work checks are carried out in accordance with UK requirements.
• Employees are paid in accordance with applicable employment and minimum wage legislation.
• Employees are not required to surrender identity documents unlawfully.
• Recruitment practices are conducted fairly and responsibly.
• No employee is subjected to threats, coercion, intimidation or exploitation.

5. Identifying and Reporting Concerns

Employees, suppliers, contractors and other relevant parties are encouraged to raise concerns if they suspect modern slavery, human trafficking, forced labour or other serious labour exploitation.

Concerns should be reported to the management of Aston Building Supplies Ltd as soon as reasonably practicable.

Reports will be treated seriously and handled appropriately. Where necessary, Aston Building Supplies Ltd may seek professional advice or refer matters to the relevant authorities.

No person should suffer retaliation for raising a genuine concern in good faith.

6. Management Responsibility

The directors and management of Aston Building Supplies Ltd are responsible for ensuring that this policy is implemented and maintained.

Management will:

• Promote awareness of modern slavery risks.
• Review relevant supply-chain risks where appropriate.
• Address concerns that are brought to their attention.
• Review this policy periodically and update it where necessary.

7. Training and Awareness

Aston Building Supplies Ltd will provide appropriate information and awareness to relevant employees and management regarding modern slavery risks, particularly where their roles involve recruitment, procurement, supplier management or supply-chain activities.

8. Breaches of This Policy

Any employee, supplier or business partner found to have engaged in or knowingly supported modern slavery, human trafficking or forced labour may be subject to appropriate action.

For suppliers or business partners, this may include suspension or termination of the business relationship, subject to contractual and legal requirements.

9. Review

This policy will be reviewed at least annually or sooner where there are significant changes to the business, legislation, supply chain or identified risks.

Approved by:
Director
Aston Building Supplies Ltd

Effective Date: 24 September 2026
Next Review Date: 24 September 2027