Modern Slavery Act Policy Statement

In accordance with the Modern Slavery Act 2015, Specialist Lines Limited (“Specialist Lines Ltd”) is committed to a work environment that is free from human trafficking, forced labour and unlawful child labour (collectively “human trafficking and slavery”). It also strongly believes that it has a responsibility for promoting ethical and lawful employment practices.

Accordingly, Specialist Lines Ltd will not knowingly use unlawful child labour or forced labour in any of the utilities and/or other commodities, products and/or services it provides, nor will it accept commodities, products and/or services from suppliers that employ or utilise child labour or forced labour.

Rationale

Human trafficking and slavery are crimes under UK and international law. These crimes exist in countries throughout the world. This policy statement thus defines Specialist Lines Ltd’s commitment to ensuring that human trafficking and slavery does not exist within its own business, but also provides how Specialist Lines Ltd will make efforts to eradicate the same from other businesses with whom it shall maintain a relationship (and especially from within its supply chain).

Specialist Lines Ltd has appointed its Head of Office as its senior compliance officer (its Anti- Slavery and Human Trafficking Officer) and will take appropriate steps to ensure not only its own compliance but also that these requirements are followed by its suppliers, subcontractors and/or business partners (collectively by its “Suppliers”) worldwide. All Suppliers are therefore required to adhere to the following:

Definitions

Human Trafficking:

The recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation.

Forced Labour:

All work or service, not voluntarily performed, that is obtained from an individual under the threat of force or penalty. Modern Slavery Act Policy Statement V2

Harmful Child Labour:

Consists of the employment of children that is economically exploitative, or is likely to be hazardous to, or interfere with, the child’s education, or to be harmful to the child’s health, or physical, mental, spiritual, moral, or social development.

Certification

Suppliers will certify compliance with this Policy and their adherence to relevant human trafficking and slavery laws in each of the relevant countries in which they operate.

Audits

Upon request, Suppliers must be able to demonstrate compliance with this Policy to the reasonable satisfaction of Specialist Lines Ltd. We may perform periodic audits on this Policy and Suppliers are expected to fully co-operate with any such audit.

Reporting

Any breach of this Policy (including by a Supplier) can be reported (in confidence, if required) by contacting Specialist Lines Ltd’s Head of Office (in her capacity as Specialist Lines Ltd’s Anti- Slavery and Human Trafficking Officer).

Consequences

Specialist Lines Ltd takes any breach of this Policy extremely seriously.

Suppliers who are found to have or be engaging in human trafficking and slavery or which refuse to cooperate with any audit to verify compliance with this Policy will be liable to have any supply agreement, arrangement or other contract with Specialist Lines Ltd terminated immediately, without compensation.

If a Supplier to Specialist Lines Ltd is found in violation of this policy, Specialist Lines Ltd will take prompt action which may include terminating any supply agreement, arrangement or other contract with that Supplier (as above). It shall also take such other (remedial) steps as the Anti- Slavery and Human Trafficking Officer shall determine to be necessary to address the violation and seek to prevent its recurrence.