Modern Slavery and Human Trafficking Statement

Background

Section 54 of the Modern Slavery Act 2015 requires large businesses to produce a statement each year setting out the steps they have taken to ensure that their business and supply chains are slavery free, or a statement that they have taken steps to do this.

Although Novion Global Limited does not currently meet the thresholds for turnover to necessitate making such a statement, our suppliers and future participants do meet this global £36 million turnover threshold.

Voluntary Statement

This statement sets out Novion Global Limited's commitment to preventing slavery and human trafficking in all our business activities and the steps we have put in place with the aim of ensuring that slavery or human trafficking is not in place in our supply chains or in any part of our business.

We all have a duty to stay alert to risks, however small, and our employees, officers and contractors are expected to report their concerns to management to act upon them.

This statement affirms our intention to act ethically in our business relationships.

Remuneration

Novion Global has a company-wide salary benchmarking process to ensure that employees are paid fairly and in line with the market standards.

Policies

We operate several internal policies to ensure that we are conducting business in an ethical and transparent manner.

Due Diligence Processes for Slavery and Human Trafficking

Novion Global undertakes due diligence when considering taking on new customers and suppliers and regularly reviews its existing suppliers and customer base.

Further Steps

We intend to take the following further steps to combat slavery and human trafficking (including but not limited to):

• Risk assess all new suppliers using the Global Slavery Index and ask them to certify that they have taken steps to eradicate modern slavery within their own organisation and supply chain;
• Where applicable, incorporate anti-slavery and human trafficking obligations into material third party vendor contracts;
• Include appropriate measures in our due diligence processes for sourcing suppliers, subcontractors and acquisitions on a risk assessed basis;
• Provide further training to relevant employees to ensure a high-level understanding of the risks of modern slavery and human trafficking; and

We have included references to the Modern Slavery Act 2015 in our policies and procedures, where relevant.

Statement

This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary.

The Management Team and Board of Directors endorse this policy statement and is fully committed to its implementation.