Modern Slavery and Human Policy

Policy Statement

Modern slavery is a crime and a grave abuse of human rights. It can manifest in various forms, including slavery, servitude, forced or compulsory labour, and human trafficking.

Arthian Ltd maintains a zero-tolerance approach to modern slavery and is committed to acting ethically, with integrity and transparency in all business dealings and relationships.

The company has implemented and continues to enforce effective systems and controls to ensure that modern slavery and human trafficking do not occur within its own operations or within any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015.

Arthian expects the same high standards from all suppliers, contractors, and business partners. As part of its contracting processes, specific prohibitions against modern slavery are included, and suppliers are expected to ensure that their own supply chains uphold equivalent standards.

Identifying potential victims of modern slavery can be challenging, as it can manifest in many ways and may be concealed within complex supply networks.

Arthian recognises its responsibility through due diligence to ensure that:

• Workers are not being exploited.

• Working conditions are safe.

• Employment, health and safety, and human rights standards are upheld, including freedom of movement and communication.

This policy applies to all individuals working for or on behalf of Arthian in any capacity, including employees, directors, officers, agency workers, volunteers, agents, contractors, consultants, and business partners.

Responsibility for the Policy

The Board of Directors holds overall responsibility for ensuring this policy complies with Arthian’s legal and ethical obligations.

The Managing Director has day-to-day responsibility for:

• Implementing and monitoring the policy.

• Auditing internal systems, controls, and procedures to ensure effectiveness in preventing or remedying modern slavery risks.

• Investigating any allegations of modern slavery within Arthian’s business or supply chains.

Line managers are responsible for ensuring that all team members reporting to them understand and comply with this policy.

Compliance

The prevention, detection, and reporting of modern slavery within Arthian’s business or supply chains—whether in the UK or abroad—is the responsibility of all individuals working for or under Arthian’s control.

All staff must avoid any activity that could lead to a breach of this policy.

If a conflict or potential breach arises, employees must report it immediately to their line manager or the Managing Director. Staff are strongly encouraged to raise any suspicions or concerns related to modern slavery as soon as possible.

If uncertain whether a specific act or treatment of workers constitutes modern slavery, employees should discuss the issue with their line manager or the Managing Director.

Arthian promotes openness and transparency, supporting anyone who raises genuine concerns in good faith—even if those concerns later prove unfounded.

No employee will face victimisation or detrimental treatment for reporting suspected instances of modern slavery.

Training and Communication

Regular training on this policy and on the risks of modern slavery within the business and its supply chains will be provided to employees as needed.

This ensures that all staff can:

• Identify signs of exploitation and modern slavery.

• Report suspected cases appropriately.

If you suspect modern slavery:

• Report it to your line manager or a senior management team member.

• You may also contact the UK Government Modern Slavery Helpline at 08000 121 700 or the police by dialling 101.

Arthian’s zero-tolerance approach to modern slavery is communicated to all suppliers, contractors, and business partners during all new or renewed contractual agreements.

Breach of the Policy

Any employee found to have breached this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.

Arthian reserves the right to terminate commercial relationships with any supplier, contractor, or business partner who breaches this policy or is found to have participated in modern slavery.