Modern Slavery & Anti-Human Trafficking - Policy

1. Policy Statement

AIC Professional Services UK Ltd prohibits all forms of slavery, servitude, forced labour, child labour and human trafficking (“modern slavery”). We will not knowingly engage with suppliers, contractors, or partners that use exploitative labour.

2. Scope

This policy applies to:

• All employees (permanent, fixed-term, temporary, contractors).

• All suppliers, subcontractors, and business partners providing goods or services to AIC globally.

• All operations under our control.

3. Responsibilities

• Board of Directors: ultimate responsibility for ensuring adequate systems to prevent modern slavery.

• Director (Accountable Officer): oversight of policy implementation, resourcing, and reporting.

• Head of Procurement: ensures supplier due diligence and contractual compliance.

• HR Director: recruitment checks, worker welfare and training.

• All employees: required to report suspicions promptly.

4. Recruitment & Labour Practices

• We conduct right-to-work checks and verify identity and employment eligibility for all staff.

• We do not retain identity documents as a condition of employment.

• We ensure that employees are paid at least the National Minimum Wage / Living Wage as appropriate and pay transparency is maintained for staff supplying labour.

5. Supplier Due Diligence & Contractual Controls

• All new strategic suppliers must complete the Supplier Due Diligence Questionnaire.

• Contracts include clauses requiring compliance with modern slavery laws and allowing audit/inspection rights.

• We reserve the right to terminate suppliers for non-compliance.

6. Detection & Reporting

Indicators of exploitation can include:

• Workers lacking freedom to leave, confiscated documents, excessive working hours, unpaid wages, evidence of coercion or deception.

• Any suspicious recruitment fees, complex subcontracting chains, or unusually low prices.

Reports should be made to: privacy@aicuk.ltd or contact@aicuk.ltd. Emergency or criminal matters must be reported to local law enforcement immediately.

7. Remediation

If exploitation is identified:

• Protect and prioritise victim safety, including referrals to statutory agencies or NGOs.

• Suspend procurement activity with the supplier pending investigation.

• Where possible, work with suppliers to implement remediation plans; if not feasible, terminate relationship and engage alternative suppliers.

8. Training & Communication

• Mandatory modern slavery awareness training for procurement, HR, security, and operations staff annually.

• Supply chain partners will be informed of AIC’s policy and contractual expectations.

9. Record Keeping

Maintain records of:

• Due diligence checks, audit reports, training completion, and incident investigations for a minimum of 7 years.

10. Review

This policy is reviewed annually by the Board or sooner if legal/regulatory change requires.