Unifi Aviation Services UK Ltd Modern Slavery and Human Trafficking Policy

POLICY STATEMENT

Unifi Aviation Services UK Ltd is committed to preventing acts of modern slavery and human trafficking within its own business and its supply chains. This policy sets out the Company’s approach to ensuring compliance with the Modern Slavery Act 2015 and promoting ethical and transparent business practices across all operations.

Prevent modern slavery, servitude, forced or compulsory labour, and human trafficking in all parts of our business and supply chains; and

Ensure that all employees, contractors, and suppliers act ethically and in compliance with the Modern Slavery Act 2015.

This policy applies to:

All employees, workers, agency staff, contractors, consultants, suppliers, and other business partners acting on behalf of Unifi Aviation Services UK Ltd.

Unifi Aviation Services UK Ltd is committed to:

Complying with all relevant legislation, including the Modern Slavery Act 2015;

Undertaking due diligence on suppliers, contractors, and business partners to identify and mitigate risks of modern slavery;

Providing appropriate training and awareness programmes for employees; and

Taking prompt and effective action where instances or suspicions of modern slavery are identified.

Definitions

Under the Modern Slavery Act 2015, Modern Slavery encompasses:

Slavery and servitude ownership or control over a person in a way that deprives them of their freedom;

Forced or compulsory labour – where people are forced to work under threat or coercion, and Human trafficking the movement or recruitment of people for the purpose of exploitation.

Risk Assessment and Due Diligence

Identify and assess potential risk areas within our operations and supply chains. Require suppliers to complete due diligence questionnaires and provide supporting evidence.

Include anti-slavery and human trafficking clauses in supplier and contractor agreements; and conduct audits or site visits where appropriate to ensure compliance.

Reporting and Whistleblowing

All Unifi employees and third parties are encouraged to report any concerns regarding modern slavery through confidential reporting channels.

All reports will be treated seriously, investigated promptly, and handled confidentially in accordance with our Whistleblowing Policy.

Training and Awareness

All Unifi employees will receive mandatory training on recognising and preventing modern slavery and human trafficking.

Additional, targeted training will be provided to employees in higher-risk roles, including those in procurement, HR, and operations.

Responsibilities

Unifi Senior Management: Ensure policy implementation and monitoring.

HR and Procurement Teams: Conduct due diligence, maintain supplier compliance, and provide training.

All Unifi Employees: Adhere to this policy and report any concerns.

Monitoring and Review

This policy will be reviewed annually and updated as required to ensure ongoing compliance with UK legislation and best practice standards.

Breaches of Policy

Any breach of this policy by an employee may result in disciplinary action, up to and including dismissal. Breaches by suppliers or contractors may result in the termination of contracts or business relationships.

Modern Slavery Statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps taken by Unifi Aviation Services UK Ltd to prevent modern slavery and human trafficking in its business and supply chains.

We are committed to conducting business ethically and with integrity in all our operations. We have implemented systems and controls to ensure that modern slavery is not taking place anywhere in our business or supply chains.

Our Supply Chains

Our supply chains include the provision of aviation ground handling services, logistics, and related support operations. We engage with suppliers who share our commitment to ethical conduct and legal compliance.

Due Diligence

We carry out due diligence on all new suppliers and monitor ongoing relationships through questionnaires, audits, and contractual clauses prohibiting modern slavery.

Training

All staff receive training to identify and report signs of modern slavery. Procurement and HR teams receive enhanced training tailored to their roles.

Ongoing Commitment

This statement will be reviewed annually and published on the Company’s website in accordance with section 54 of the Modern Slavery Act 2015.

Supplier Code of Conduct

Unifi Aviation Services UK Ltd expects all suppliers, contractors, and business partners to uphold the highest standards of ethical conduct and comply with all applicable laws and regulations, including the Modern Slavery Act 2015.

Legal Compliance

Suppliers must comply with all applicable laws, including those relating to labour, employment, health and safety, and modern slavery.

Employee Standards

Suppliers must:

Prohibit all forms of forced, bonded, or involuntary labour.

Prohibit child labour and ensure legal minimum working ages are observed.

Provide fair wages, working hours, and conditions in accordance with applicable law.

Health and Safety

Suppliers must provide a safe and hygienic working environment and take all necessary measures to prevent accidents and injury.

Ethical Conduct

Suppliers must conduct business ethically, transparently, and without bribery, corruption, or exploitation.

Monitoring and Audits

Suppliers shall maintain accurate records and permit Unifi Aviation Services UK Ltd to conduct audits or assessments to verify compliance.

Reporting Violations

Suppliers must encourage employees to report concerns confidentially and must not retaliate against anyone who raises a concern in good faith.

Non-Compliance

Failure to comply with this Code of Conduct may result in suspension or termination of the business relationship.