Modern Day Slavery Act 2015

Gardner Engineering Limited recognises that slavery and human trafficking remains a hidden blight on our global society. The aim of the Company is to identify our responsibility by alerting staff to the risks, however small, in our business and in the wider supply chain. Staff are expected and encouraged to report concerns to management, where they are expected to act upon them. Company activities are varied through multiple disciplined areas and sectors, and likewise, we have a multi-disciplined supply chain to support us through the different aspects and provisions of our business. We are committed to ensuring that there is no modern-day slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy Statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. This Policy takes into account and supports the policies, procedures, and requirements documented in our Internal Management System. The implementation and operation of this management system underlines our commitment to this policy statement.

Formal procedures concerning slavery and human trafficking have been established, including disciplinary procedures where they are breached. Additional procedures ensure that this policy is understood and communicated to all levels of the company, and that it is regularly reviewed by the Directors to ensure its continuing suitability and relevance to company activities. The Company will achieve these aims by our initiative to identify and mitigate risk in the following ways (but not limited to):

• More stringent vetting and investigation of our supply chain (contractors, sub-contractors, policies, contracts etc.).
• Continually audit & review our practices, checking all employees are paid the minimum wage and have the right to work.
• We encourage the reporting of concerns and the protection of whistle blowers.
• The company will not knowingly support or deal with any business involved in slavery or human trafficking.
• We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors comply with our values.

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff.