Modern Slavery Policy Statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced or compulsory labour, and human trafficking, all of which involve the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Cibes Lift Group has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in our own business or within our supply chains.

Cibes Lift Group is committed to transparency in our business and in our approach to tackling modern slavery, in line with our obligations under the Modern Slavery Act 2015, including the requirement to publish an annual modern slavery and human trafficking statement.

We expect the same high standards from all contractors, suppliers, and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory, or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We also expect our suppliers to hold their own suppliers to the same high standards.

Scope

This policy applies to all employees and persons working on behalf of Cibes Lift Group in any capacity, including employees at all levels, directors, officers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

This policy does not form part of any employee’s contract of employment, and the Company may amend it at any time.

Roles and Responsibilities

Overall responsibilities and accountabilities related to the ownership, implementation, and review of this policy are informed by the requirements of the Modern Slavery Act 2015.

In addition:

• Managing Director (UK)
  Has overall responsibility for ensuring this policy complies with our legal and ethical
  obligations and that those under our control comply with it.
• Head of HR (UK)
  Has primary and day-to-day responsibility for implementing this policy, monitoring its
  effectiveness, addressing any related queries, and ensuring procedures are in place and
  effective to counter modern slavery.
• Management at all levels
  Are responsible for ensuring that those reporting to them understand and comply with this
  policy and receive adequate and periodic training on modern slavery risks, including within
  supply chains.

Policy Requirements

1. The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for, or on behalf of, Cibes Lift Group.
2. All colleagues must avoid any activity that might lead to, or suggest, a breach of this policy.
3. All colleagues must notify their manager or the HR department as soon as possible if they believe or suspect that a breach of this policy has occurred or may occur in the future.
4. Colleagues are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business or supply chains, at any supplier tier, at the earliest possible stage.
5. Where a breach of this policy has occurred, or is suspected to have occurred, the HR department must be notified as soon as possible.
6. If colleagues are unsure whether a particular act, the treatment of workers, or working conditions within any tier of our supply chains constitute modern slavery, they must raise the matter with their manager or HR.
7. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they later prove to be mistaken. We are committed to ensuring that no one suffers any detrimental treatment as a result of reporting concerns in good faith. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. Any colleague who believes they
   have suffered such treatment should inform their manager, HR, or the Directors immediately. Where appropriate, concerns may also be raised under the Company’s Whistleblowing Policy.
8. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship and reinforced as appropriate thereafter.

Responding to Modern Slavery Concerns

Where modern slavery is suspected or identified within our operations or supply chain, Cibes Lift Group will:

• Immediately assess the concern and take steps to protect potentially affected individuals.
• Conduct an appropriate investigation led by HR and senior management.
• Report matters to the relevant authorities where criminal activity or safeguarding concerns are identified.
• Work with customers, suppliers and relevant agencies to safeguard victims and prevent further exploitation.
• Require suppliers or contractors to implement corrective actions within agreed timescales.
• Suspend or terminate business relationships where suppliers fail to address identified breaches or where serious violations are confirmed.
• Review and strengthen due diligence, monitoring and procurement controls to prevent recurrence.
• Record findings, actions taken and lessons learned as part of our continual improvement process.

Recruitment and Right to Work

9. To prevent illegal working and exploitation, all prospective employees are required to provide evidence of their right to work in the UK prior to commencing employment, in line with Home Office requirements. The HR department will review right-to-work documentation regularly to ensure it remains current and accurate. We are committed to fair, lawful, and transparent recruitment practices and do not tolerate recruitment fees being charged to workers.

10. Any colleague who breaches this policy will be subject to formal action under the Company’s disciplinary procedure, which may result in dismissal for misconduct or gross misconduct.

11. We may terminate our relationship with any individual or organisation working on our behalf if they are found to be in breach of this policy.

Due Diligence and Risk Management

Cibes Lift Group seeks to identify and mitigate the risk of modern slavery within its operations and supply chains. This includes proportionate due diligence during supplier onboarding, contractual controls, and periodic review of supplier practices where appropriate.

Communication and Training

All directors and senior management will be briefed on the importance of this policy. Relevant training will be provided to employees as appropriate to their role.