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Modern Slavery Act Policy

1. GENERAL

1.1   Last Mile Infrastructure Group Limited (“Company”) design and build electricity, gas and water utility infrastructure at residential and commercial property sites. The Company is fully licensed to own and operate the gas, electricity and water networks it installs.

2. POLICY STATEMENT

It is the Company’s Policy to conduct its business in a fair, open and honest manner and to take a zero- tolerance approach to all slavery, servitude, forced or compulsory labour (including child labour) and human trafficking (each and together referred to as “Modern Slavery”). In order to achieve this, the Company is committed to:

2.1. Acting professionally, fairly and with integrity in all business dealings and relationships wherever we operate.

2.2. Prohibiting all forms of Modern Slavery, all of which are a crime and a violation of fundamental human rights and have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain

2.3. Compliance with all laws relevant to countering modern slavery including the Modern Slavery Act 2015, approved Codes of Practice and industry recognised guidelines.

2.4. Ensuring, so far as it is reasonably practicable to do so, that contracts contain provisions allowing for automatic termination for breach of the Modern Slavery Act 2015.

2.5. Investigating thoroughly any actual or suspected breach of this Policy, or the spirit of this Policy.

2.6. Implementing effective systems and controls to ensure Modern Slavery is not taking place anywhere in our business or in any of our supply chains.

2.7. Consulting with staff and providing appropriate information, instruction and training to ensure all staff are aware of their Modern Slavery Act 2015 obligations.

2.8. Undertaking an ongoing programme of audit and ensuring that enough resource is allocated as required for the implementation of this Policy.

2.9. Communicating this Policy to staff, contractors, suppliers, customers and other interested parties.

3. SCOPE

3.1. The Company and all related subsidiary undertakings are within the scope of this document. We expect the same high standards from all our contractors, suppliers and other business partners.

 

4. DEFINITIONS

4.1. Unless a contrary intention is evident, or the context requires otherwise, words or expressions contained in this document shall have the same meaning as set out in the Articles of Association of the Company and the following defined terms shall have the specific meanings given to them below:

Board means the Chairperson, Executive Directors and Non-executive Directors of the Company.

Chairperson means a Member of the Board who is appointed pursuant to article 11 of the Company’s Articles of Association.

Chief Executive Officer means a Member of the Board who is appointed pursuant to article 20.1 of the Company’s Articles of Association and so designated.

Committee means a committee appointed by the Board, which reports to the Board.

Company means Last Mile Infrastructure Group Limited.

Company Secretary means the person who is appointed pursuant to article 72 of the Company’s Articles of Association.

Employee means a person paid via the payroll of the Company, or for whom the Company has responsibility for making payroll arrangements, but excluding Non-executive Directors.

Executive Director means a Member of the Board who is appointed pursuant to article 20.1 of the Company’s Articles of Association.

Non-executive Director means a Member of the Board who is appointed pursuant to article 20.2 of the Company’s Articles of Association.

Policy means this policy document.

5. ROLES AND RESPONSIBILITIES

5.1. The Board has overall responsibility for maintaining the corporate governance framework of the Company, including this document.

5.2. The Company Secretary has responsibility for:

5.2.1. Publicising the existence of the corporate governance framework and all associated controlled documents;

5.2.2. Ensuring all corporate governance framework documents, policy documents and Committee terms of reference are published on the intranet;

5.2.3. Maintaining a register of all corporate governance framework documents, policy documents and Committee terms of reference;

5.2.4. Ensuring all corporate governance framework documents, policy documents and Committee terms of reference are reviewed no later than their agreed review date.

6. DISTRIBUTION AND IMPLEMENTATION

6.1. Distribution Plan

6.1.1. This document will be made available on the Company intranet and internet site.

6.1.2. A global communication will be issued to all Employees notifying them of the release of this document.

6.2. Training Plan

6.2.1. A training needs analysis will be undertaken with Employees affected by this document.

6.2.2. Based on the findings of that analysis appropriate training will be provided as necessary.

7. MONITORING

7.1. Compliance

7.1.1. Compliance with this document will be monitored by the Risk and Compliance Committee.

7.1.2. This policy will be reviewed annually.

8. ASSOCIATED DOCUMENTATION

8.1. Not applicable.

9. REFERENCES

9.1. None

Please see below our policy on Modern Slavery Act Policy which is available for download below.