Data Privacy Notice

Real-Time Consultants Limited ("we" or "us") trading as RT Consulting is a provider of change and transformation consultancy services, committed to protecting and respecting your privacy.

This statement (together with our Terms of Use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us will be processed by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the EU General Data Protection Regulation, the data controller is Real-Time Consultants Ltd (Z5459808), Registered at Teme House, Whittington Road, Worcester, WR5 2RY. England.

Data we collect

In order to provide the best possible service to our associates and clients the data we collect, store and process relating to you may include:

As an Associate:

• Your name
• Your address
• Your email address
• Your Telephone number
• Your CV/ Work History
• Your Job Preferences: Role, Location, Salary
• Work related information you provide: Education & Training Certificates
• Our communications with you by email and telephone
• Any Communications with the client relating to the role and you as the consultant

As a Client Contact:

• Your name
• Your email address
• Your telephone number
• The company you work for and you role in that company
• Our communications with you by email and telephone relating to consultants we have provided for roles at your company.

If we assign you to a client the data we collect, store and process relating to you will include:

• Passport
• Visas & Work Permits where applicable
• Date of Birth
• National Insurance number
• Offers and Placements
• Employment References
• Outcome of Criminal Record and Security Clearance checks where applicable
• Financial Information including payroll details and HMRC data
• Our communications with you by email and telephone
• Any Communications with the client relating to your assignment

If the contract of employment is directly with us, the data we collect, store and process relating to you will include:

• Bank details
• Timesheets
• Salary
• Salary adjustments
• Payment records

Where we obtain your information

Associates:

• Registering or applying for jobs via our website
• CV or application from Job boards
• LinkedIn profile
• Referral by friends / colleagues

Clients:

• Directly from you
• From your company website
• Via a colleague identifying you as a point of contact
• From third parties including associates, LinkedIn and networking.

How we use your data

We will process and store your data in order to provide our services to you, and for contractual and legal reasons if we have assigned you to a project, or assigned a consultant with your company.

We may process sensitive personal data where it has been included in the information you provide us, e.g. if you include information in your CV. We may also be required to conduct a criminal records check against your details. We have processes to limit our use and disclosure of this sensitive data other than where required by law.

Our legal basis for processing your data

The EU General Data Protection Regulation (GDPR) legal basis under which we collect, process and retain data about you is classified as

• “Contract” – It will be necessary to process your personal data in order to fulfil the obligations of providing a service to you, or to take steps to enter into a contract with you.
• “Legitimate Interest” - We are a business engaged in the provision of consultancy services and we will need to process your data in order to provide these services.
• “Legal Obligation” – We may be legally required to process and retain your personal data for inspection by a law enforcement agency or government body.
• “Consent” - We may rely on your consent to process your personal data for one or more specific purposes. You have the right to withdraw your consent to this particular processing at any time

How we share your data

We will only share your information with prospective clients with your express consent.

Disclosure of your information

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 736 of the Companies Act 1985.

We may disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If Real-Time Consultants Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of Real-Time Consultants Ltd, our customers, or others.

Your Rights

You have the right to access and view the personal data we hold about you. You have the right to have the personal data we hold about you to be changed, corrected or deleted. You have the right to ask us not to process your personal data for marketing purposes. You can exercise the right at any time by contacting us at compliance@rtc.co.uk.

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.

Please check these policies before you submit any personal data to these websites.

Data Retention and Right to be forgotten

We keep your data in accordance with the following data retention periods:

• If you have been assigned to a client and the contract was through us then we must legally keep your record for up to 7 years after the contract completed.
• If we have assigned a consultant to your company and the contract was through us then we must legally keep all records that relate to the consultant that may be inspected by law for up to 7 years after the contract completed.

Otherwise, we will keep your record for up to 2 years and thereafter will either gain your consent to continue processing your data or remove you completely from our systems.

Under the GDPR there is a “right to be forgotten” which is only relevant where there is no legal requirement for us to retain the information as defined above. If there is no legal requirement for us to keep your information and you request to be deleted this will be done within 14 days of your request.

Some of your data may still exist within our systems but this data will be put beyond use and cannot be readily accessed by operational staff, systems or processes.

Cookies Policy

When you visit our websites we may collect information, including information collected through using Google Analytics (www.google.com/analytics, www.leadforensics.co.uk, www.zendesk.co.uk), about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve the Site and to deliver a better and more personalised service. They enable us:

• To estimate our audience size and usage pattern.
• To store information about your preferences, and so allow us to customise the Site according to your individual interests.
• To speed up your searches.
• To recognise you when you return to the Site.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of the Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to the Site.

Where your data will be stored

All your data will be stored securely on our IT system in the UK.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Some basic personal data is provided to an email service provider (when consented to) for the purpose of email marketing.

Access to your Data

Access to your data is restricted to our staff that have a legitimate reason to see it, all of which are bound by confidentiality clauses.

What if you have Objections?

If you have an objection to the data that is being stored relating to you, how it is being processed, who has access to it etc. these should be raised to the DPO compliance@rtc.co.uk who will investigate and take the appropriate action.

Who you should contact if data needs amending?

If the data we hold on you changes please inform the DPO at compliance@rtc.co.uk who will process your request.

How do you access the data we hold on you?

For access to your data please consult with the DPO at compliance@rtc.co.uk.

Changes to our Privacy Statement

Any changes we may make to our privacy statement in the future will be posted on this page and, where appropriate, notified to you by e-mail.

Contact

Questions, comments and requests regarding this privacy statement are welcomed and should be addressed to compliance@rtc.co.uk.

Terms of Use

This page (together with the documents referred to on it) tells you the Terms Of Use on which you may make use of Phixos Limited and its subsidiaries (Symbiotics Limited, AMI Learning Limited and Real Time Consultants Limited) websites (the Site(s)), as a registered user. Please read these Terms Of Use carefully before you start to use the Site(s). By using the Site(s), you indicate that you accept these Terms Of Use and that you agree to abide by them. If you do not agree to these Terms Of Use, please refrain from using the Site(s).

Information About Us

www.phixos.co.uk, www.amilearning.co.uk, www.ruas.co.uk, www.symbioticsltd.com, www.rtc.co.uk, www.realtimeconsultants.co.uk, www.realtimeengineering.co.uk, www.realtimeexecutives.co.uk, www.compertum.co.uk, www.rpasportal.co.uk are the websites operated by Phixos Limited and its subsidiaries ("we" or "us"). We are a limited company registered under company number 02667200 and have our registered office at - Teme House, Whittington Road, Worcester, WR5 2RY. England.

Accessing The Site(s)

Access to the Site(s) is permitted on a temporary basis, and we reserve the right to withdraw or amend the service we provide on the Site(s) without notice (see below). We will not be liable if for any reason, including but not limited to the resolution of technical problems, routine maintenance or improvement, the Site(s) is unavailable at any time or for any period.

From time to time, we may restrict access to some parts of the Site(s), or the entire Site(s), to users who have registered with us.

You must be registered using a valid personal email address that you access regularly. We reserve the right to close without notice accounts registered with someone else's email address or with temporary email addresses.

You are responsible for any information you submit to the website and for ensuring that all information you supply is true, accurate, up-to-date and not misleading or likely to mislead or deceive. Please refer to our Acceptable Use Policy.

If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures, you must treat such information as confidential and you must not disclose it to any third party. We have the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our opinion you have failed to comply with any of the provisions of these Terms Of Use.

You must notify us immediately if you know or believe that your password is in the possession of someone else or if it is being or may be used in an unauthorised way.

We will not be liable for any loss that you may incur as a result of someone else using your password or account, either with or without your knowledge. However, you could be held liable for losses incurred by us or another party due to someone else using your account or password.

When using the Site(s), you must comply with the provisions of our Acceptable Use Policy. You are responsible for making all arrangements necessary for you to have access to the Site(s). You are also responsible for ensuring that all persons who access the Site(s) through your internet connection are aware of these Terms Of Use, and that they comply with them.

Intellectual Property Rights

We are the owner or the licensee of all intellectual property rights in the Site(s), and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

You may print off one copy, and may download extracts, of any page(s) from the Site(s) for your personal reference and you may draw the attention of others within your organisation to material posted on the Site(s).

You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.

Our status (and that of any identified contributors) as the authors of material on the Site(s) must always be acknowledged.

You must not use any part of the materials on the Site(s) for commercial purposes without obtaining a prior licence to do so from us or our licensors.

No framing, harvesting, "scraping" or other manipulation of the material on the Site(s) is permitted without obtaining a prior licence to do so from us or our licensors.

You must not, nor attempt to, decipher, disassemble, reverse engineer or modify any of the software, coding or information comprised in the Site(s).

If you print off, copy or download any part of the Site(s) in breach of these Terms Of Use, your right to use the Site(s) will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

Reliance on Information Posted

Commentary and other materials posted on the Site(s) are not intended to amount to advice on which reliance should be placed. We therefore disclaim all liability and responsibility arising from any reliance placed on such materials by any visitor to the Site(s), or by anyone who may be informed of any of its contents.

The Site(s) Changes Regularly

We aim to update the Site(s) regularly, and may change the content at any time. If the need arises, we may suspend access to the Site(s), or close it indefinitely. Any of the material on the Site(s) may be out of date at any given time, and we are under no obligation to update such material.

Our Liability

The material displayed on the Site(s) is provided without any guarantees, conditions or warranties as to its accuracy. To the extent permitted by law, we, other members of our group of companies and third parties connected to us hereby expressly exclude:

All conditions, warranties and other terms which might otherwise be implied by statute, common law or the law of equity.

• Any liability for any direct, indirect or consequential loss or damage incurred by any user in connection with the Site(s) or in connection with the use, inability to use, or results of the use of the Site(s), any websites linked to it and any materials posted on it, including, without limitation any liability for:
• • loss of income or revenue
  • loss of business;
  • loss of profits or contracts;
  • loss of anticipated savings;
  • loss of data;
  • loss of goodwill;
  • wasted management or office time;
  • and for any other loss or damage of any kind, however arising and whether caused by tort (including negligence), breach of contract or otherwise, even if foreseeable, provided that this condition shall not prevent claims for loss of or damage to your tangible property or any other claims for direct financial loss that are not excluded by any of the categories set out above.

This does not affect our liability for death or personal injury arising from our negligence, nor our liability for fraudulent misrepresentation or misrepresentation as to a fundamental matter, nor any other liability which cannot be excluded or limited under applicable law.

Information About You and Your Visits to The Site(s)

We process information about you in accordance with our Privacy Statement. By using the Site(s), you consent to such processing and you warrant that all data provided by you is accurate.

Transactions Concluded Through The Site(s)

Contracts for employment assignments or placements and any other contracts arising from or formed through the Site(s) or as a result of visits made by you are governed by these Terms Of Use.

Uploading Material to The Site(s)

Whenever you make use of a feature that allows you to upload material to the Site(s), or to make contact with other users of the Site(s), you must comply with the content standards set out in our Acceptable Use Policy. You warrant that any such contribution does comply with those standards, and you indemnify us for any breach of that warranty.

Any material you upload to the Site(s) will be considered non-confidential and non-proprietary, and we have the right to use, copy, distribute and disclose to third parties any such material for any purpose. We also have the right to disclose your identity to any third party who is claiming that any material posted or uploaded by you to the Site(s) constitutes a violation of their intellectual property rights, or of their right to privacy.

We will not be responsible, or liable to any third party, for the content or accuracy of any materials posted by you or any other user of the Site(s). We have the right to remove any material or posting you make on the Site(s) if, in our opinion, such material does not comply with the content standards set out in our Acceptable Use Policy.

Viruses, Hacking and Other Offences

You must not misuse the Site(s) by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to the Site(s), the server on which the Site(s) is stored or any server, computer or database connected to the Site(s). You must not attack the Site(s) via a denial-of-service attack or a distributed denial-of service attack.

By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use the Site(s) will cease immediately.

We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of the Site(s) or to your downloading of any material posted on it, or on any website linked to it.

Linking to The Site(s)

You may link to our site(s) home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it, but you must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists.

You must not establish a link from any website that is not owned by you.

The Site(s) must not be framed on any other website, nor may you create a link to any part of the Site(s) other than the home page(s). We reserve the right to withdraw linking permission without notice. The website from which you are linking must comply in all respects with the content standards set out in our Acceptable Use Policy.

If you wish to make any use of material on the Site(s) other than that set out above, please address your request to data@blakebrookgroup.co.uk.

Links From The Site(s)

Where the Site(s) contains links to other websites and resources provided by third parties, these links are provided for your information only as a convenience to users. We have no control over the contents of those websites or resources, and accept no responsibility for them or liability for any loss or damage that may arise from your use of them and your use of those websites and resources shall be entirely at your own risk.

Variations

We may revise these Terms Of Use at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we made, as they are binding on you. Some of the provisions contained in these Terms Of Use may also be superseded by provisions or notices published elsewhere on the Site(s).

No waiver

Failure to exercise, or any delay in exercising, any right or remedy provided under these Terms Of Use or by law shall not constitute a waiver of that (or any other) right or remedy, nor shall it preclude or restrict any further exercise of that (or any other) right or remedy.

Severability

If any provision of the Terms Of Use (or part of any provision) is found by any court or other authority of competent jurisdiction to be invalid, illegal or unenforceable, that provision or part-provision shall, to the extent required, be deemed not to form part of the Terms Of Use, and the validity and enforceability of the other provisions of the Terms Of Use shall not be affected.

Jurisdiction and Applicable Law

The English courts will have exclusive jurisdiction over any claim arising from, or related to, a visit to the Site(s) although we retain the right to bring proceedings against you for breach of these conditions in your country of residence or any other relevant country. These Terms Of Use and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the law of England and Wales.

Your Concerns

If you have any concerns about material which appears on the Site(s), please contact data@blakebrookgroup.co.uk.

Thank you for visiting the Site(s).

This Acceptable Use Policy sets out the terms between you and us under which you may access our websites www.phixos.co.uk, www.amilearning.co.uk, www.ruas.co.uk, www.symbioticsltd.com, www.rtc.co.uk, www.realtimeconsultants.co.uk, www.realtimeengineering.co.uk, www.realtimeexecutives.co.uk, www.compertum.co.uk, www.rpasportal.co.uk (the Site(s)). This Acceptable Use Policy applies to all users of, and visitors to, the Site(s).

Your use of the Site(s) means that you accept, and agree to abide by, all the policies in this Acceptable Use Policy, which supplement the Terms Of Use for our Site(s).

Our Site(s) are operated by Phixos Limited and its subsidiaries (Symbiotics Limited, AMI Learning Limited and Real Time Consultants Limited) ("we" or "us"). We are a limited company registered in England and Wales under company number 02667200 and have our registered office at - Teme House, Whittington Road, Worcester, WR5 2RY. England

Prohibited Uses

You may use the Site(s) only for lawful purposes. You may not use the Site(s):

• In any way that breaches any applicable local, national or international law or regulation.
• In any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect.
• For the purpose of harming or attempting to harm minors in any way.
• To send, knowingly receive, upload, download, use or re-use any material which does not comply with our content standards (see below).
• To transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam).
• To knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.

You also agree:

• Not to reproduce, duplicate, copy or re-sell any part of the Site in contravention of the provisions of our Terms Of Use.
• Not to access without authority, interfere with, damage or disrupt:
• any part of the Site(s);
• any equipment or network on which the Site(s) is stored;
• any software used in the provision of the Site(s); or
• any equipment or network or software owned or used by any third party.

Interactive Services

We may from time to time provide interactive services on the Site(s), including, without limitation:

• Chat rooms
• Bulletin boards
• Forums
• Blogs

Where we do provide any interactive service, we will provide clear information to you about the kind of service offered, if it is moderated and what form of moderation is used (including whether it is human or technical).

We will do our best to assess any possible risks for users (and in particular, for children) from third parties when they use any interactive service provided on the Site(s), and we will decide in each case whether it is appropriate to use moderation of the relevant service (including what kind of moderation to use) in the light of those risks. However, we are under no obligation to oversee, monitor or moderate any interactive service we provide on the Site(s), and we expressly exclude our liability for any loss or damage arising from the use of any interactive service by a user in contravention of our content standards (see below), whether the service is moderated or not.

The use of any of our interactive services by a minor is subject to the consent of their parent or guardian. We advise parents who permit their children to use an interactive service that it is important that they communicate with their children about their safety online, as moderation is not foolproof. Minors who are using any interactive service should be made aware of the potential risks to them.

Where we do moderate an interactive service, we will normally provide you with a means of contacting the moderator, should a concern or difficulty arise.

Content Standards

These content standards apply to any and all material which you contribute to the Site(s) (contributions), and to any interactive services associated with it.

You must comply with the spirit of the following standards as well as the letter. The standards apply to each part of any contribution as well as to its whole.

Contributions must:

• Be accurate (where they state facts).
• Be genuinely held (where they state opinions).
• Comply with applicable law in the UK and in any country from which they are posted.

Contributions must not:

• Contain any material which is defamatory of any person.
• Contain any material which is obscene, offensive, hateful or inflammatory.
• Promote sexually explicit material.
• Promote violence
• Promote discrimination based on race, sex, religion, nationality, disability, sexual orientation or age.
• Infringe any copyright, database right or trade mark of any other person.
• Be likely to deceive any person.
• Be made in breach of any legal duty owed to a third party, such as a contractual duty or a duty of confidence.
• Promote any illegal activity
• Be threatening, abuse or invade another's privacy, or cause annoyance, inconvenience or needless anxiety.
• Be likely to harass, upset, embarrass, alarm or annoy any other person.
• Be used to impersonate any person, or to misrepresent your identity or affiliation with any person.
• Give the impression that they emanate from us, if this is not the case.
• Advocate, promote or assist any unlawful act such as (by way of example only) copyright infringement or computer misuse.

Suspension and Termination

We will determine, in our discretion, whether there has been a breach of this Acceptable Use Policy through your use of the Site(s). When a breach of this policy has occurred, we may take such action as we deem appropriate.

Failure to comply with this Acceptable Use Policy constitutes a material breach of the Terms Of Use, upon which you are permitted to use the Site(s), and may result in our taking all or any of the following actions:

• Immediate, temporary or permanent withdrawal of your right to use the Site(s).
• Immediate, temporary or permanent removal of any posting or material uploaded by you to the Site(s).
• Issue of a warning to you.
• Legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach.
• Further legal action against you.
• Disclosure of such information to law enforcement authorities as we reasonably feel is necessary.

We exclude liability for actions taken in response to breaches of this Acceptable Use Policy. The responses described in this policy are not limited, and we may take any other action we reasonably deem appropriate.

Changes to the Acceptable Use Policy

We may revise this Acceptable Use Policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are legally binding on you. Some of the provisions contained in this Acceptable Use Policy may also be superseded by provisions or notices published elsewhere on the Site(s).

It is the policy of Blakebrook AG, and all its subsidiary companies (Phixos Limited, Symbiotics Limited, AMI Learning Limited and Real Time Consultants Limited), to conduct all of its business in an honest and ethical manner. Blakebrook AG takes a zero-tolerance approach to bribery and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships wherever BlakeBrook AG operates; and implementing and enforcing effective systems to counter bribery.

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

Blakebrook AG does not permit the making of any inappropriate promises, or gifts, to others in order to achieve unfair advantage or benefit.

Blakebrook AG resists any efforts made by others (particularly existing or potential suppliers, customers or clients) to affect any BlakeBrook AG decision making process in order to achieve unfair advantage or benefit.

Blakebrook AG commits to always reporting and/or documenting any suspicions of non-compliance with this policy through the reporting mechanism provided.

Blakebrook AG does not make contributions to political parties. Blakebrook AG may make charitable donations when they are ethical and legal under local laws and practices.

Any employee found to have contravened this Policy will be subject to the Disciplinary Dismissal Policy which may find the contravention to be gross misconduct and the person concerned summarily dismissed.

“In this document, all references to Blakebrook refer to Blakebrook AG and its subsidiaries (Phixos Limited, Symbiotics Limited, AMI Learning Limited and Real Time Consultants Limited) and its trading divisions (RUAS, Phixos, Real Time Consultants, RT Consulting, Real Time Engineering).”

Introduction

Slavery and human trafficking remains a hidden blight on our global society. Blakebrook have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain. Staff are expected to report concerns and management are expected to act upon them.

This statement is made pursuant to section 51(1) of the Modern Slavery Act 2015 and sets out the steps that we have taken during the financial year ending 31 December 2017, to ensure that our business as well as our supply chains are free from slavery and human trafficking.

Organisational Structure And Operations

Blakebrook is a privately owned company with a group wide turnover of approximately EUR 30 Million, employing in excess of 120 employees throughout the UK and the European Union. Blakebrook offers aviation, aerospace, rail, automotive and defence resourcing solutions supporting OEM’s, operators and support businesses.

Blakebrook principally operates in the UK and the EU and has four business streams comprising of Technical Recruitment Solutions, Systems Software and Solutions, Resource UAS and Symbiotic Performance Solutions.

NATURE OF OUR SUPPLY CHAIN

Blakebrook’s supply chains include the sourcing of office equipment and suppliers principally related to the provision of recruitment, training and engineering services.

In addition, some of our businesses provide manpower services through relationships with limited companies.

POLICIES RELATING TO SLAVERY AND HUMAN TRAFFICING

Our modern slavery policy reflects our commitment to acting ethically and with integrity in all our business activities and relationships and implementing and enforcing effective procedures and controls to minimise the risks of modern slavery practices infiltrating our business operations or supply chains.

We also make sure our suppliers are aware of our policies and ask that they adhere to the same high standards.

RISK ASSESSMENT

We used the Risk Management processes to assess which of our own activities and supply chains represented the highest risks in respect of slavery or human trafficking, in particular, geography, sector and cost of supply.

DUE DILIGENCE PROCESSES IN RELATION TO SLAVERY

In order to monitor and mitigate the risks of slavery occurring within our supply chains we followed a due diligence process in relation to new suppliers identified as being high risk according to the risk assessment procedures described above. Also, as part of our initiative to identify and mitigate risk:

• Where possible we have built long standing relationships with suppliers and made it clear our expectations of their business behaviour.
• With regards to national or international supply chains, where possible, our point of contact is with a UK company or branch and we expect their entities to have suitable anti-slavery and human trafficking policies and processes. We expect each entity in the supply chain to, at least, adopt ‘one-up’ due diligence on the next link in the chain. It is not practical for us (and every other participant in the chain) to have a direct relationship with all links in the supply chain.
• Where non UK based companies form part of our supply chain we sought the same assurances that they comply with the letter and ethos of the Modern Slavery Act.
• We have in place systems to encourage the reporting of concerns and the protection of whistle blowers, and there has been no incidences reported to us within the period of this statement.

SUPPLIER ADHERENCE TO OUR VALUES

We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors comply with our values.

The Directors are responsible for compliance in their respective Business Units and for their supplier relationships.

STAFF TRAINING

We have provided training to relevant members of staff at Induction to ensure that they understand the risks of modern slavery infiltrating our business or supply chains and the effective operation of our policies and procedures to ensure the mitigation of this risk.

All Directors have been briefed on the subject.

We make specific provision in our Whistleblowing Policy including the protection of those who whistleblow in relation to modern slavery.

OUR EFFECTIVENESS

We use the following KPI’s to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business supply chains:

• Completion of audits as part of the Quality process. Findings - No issues foundli>
• Level of communication and personal contact with next link in the supply chain and their understanding of, and compliance with, our expectations. Findings - Level of understanding and compliance verified.

This statement is made pursuant of section 51(1) of the Modern Slavery Act 2015 and constitutes our Group’s Slavery and Human Trafficking Statement for the current financial year ending 31st December 2017.

John Larkin
CHAIRMAN

16.11.17