SPR02.3s Springpod Modern Slavery Statement v1.3

This Modern Slavery and Human Trafficking Statement sets out the steps Springpod has taken to prevent modern slavery and human trafficking within our operations and supply chains.

While Springpod is not currently subject to the reporting requirements of section 54 of the Modern Slavery Act 2015, we publish this statement voluntarily as part of our commitment to ethical business practices, transparency and responsible supply chain management.

This statement is reviewed annually and approved by senior management.

Springpod primarily operates within the UK and works with a predominantly domestic supplier base. Our key supplier categories include:

• Software and cloud service providers

• Marketing, creative and digital service providers

• Professional services including legal, finance and compliance

• Recruitment and staffing support

• Event and education delivery partners

While our direct operations present a low inherent risk of modern slavery, we recognise that certain sectors and outsourced services may present elevated risk and therefore apply proportionate, risk based controls.

We are committed to conducting ourselves honestly and with integrity, striving for fairness in everything we do, including how we treat our employees.

We ensure that all our staff know they can confidentially report any concerns, including cases of unethical behaviour, and we review every reported case and take appropriate action.

We have policies in place that ensure our employment practices mitigate the risks identified in the Modern Slavery Act, including:

• Workers are not subject to forced labour and are free to terminate their employment at any time, without penalty, given the length of notice specified.

• Workers will not be charged any fees for recruitment.

• The confiscation or withholding of any worker identity documents is strictly prohibited.

• Our workplace is free of harsh or inhumane treatment, as outlined in our Dignity at Work Policy and reinforced through staff training.

• All workers, irrespective of their nationality, are treated fairly and equally.

• All workers are paid at least the minimum wage required by law, and salaries are paid directly to the staff member at regular intervals.

• Workers are only required to work the legally mandated number of hours.

• All overtime is voluntary, and no worker will be required to work overtime under the threat of penalty or dismissal.

Springpod applies a risk-based approach to identifying and managing modern slavery risks within its supply chain.

Supplier risk assessments consider:

• Country of operation

• Nature of services provided

• Use of labour-intensive or outsourced workforces

• Contract value and dependency

• Length and complexity of the supplier relationship

Suppliers are categorised as low, medium or higher risk.

Where medium or higher risk is identified, Springpod may apply enhanced due diligence measures, including:

• Confirmation of modern slavery policies and controls

• Contractual modern slavery compliance clauses

• Additional supplier questionnaires or evidence requests

• Periodic review and reassessment

Risks identified are recorded, monitored and escalated where necessary.

During the reporting period, no known incidents of modern slavery or human trafficking were identified within Springpod’s operations or supply chain.

Springpod recognises that the absence of reported incidents does not equate to the absence of risk and remains committed to continuous monitoring and improvement.

Where concerns are identified, Springpod will take appropriate action including investigation, supplier engagement, remediation, and where necessary termination of relationships.

We understand that Modern Slavery risk is not static, and we will continue to re-assess our approach. To assess the effectiveness of our approach, we will review the following KPIs paying close attention to:

• The proportion of internal policies that have been reviewed in line with the Modern Slavery Act

• The proportion of third parties who have been evaluated against our modern Slavery risk assessment tool

• The number of Modern Slavery breaches that have been reported to us or discovered through our due diligence.

• The proportion of controls executed as per our Modern Slavery policy

• The effective and timely conclusion of any identified issues

• The proportion of relevant staff who have completed Modern Slavery training

Since being established, we have:

• Improved Governance Policies

• appointed a responsible person overall responsibility for Modern Slavery

• launched a Modern Slavery Policy

• embedded Modern Slavery into our Third-Party Management programme

• reviewed our HR policies

• built a picture of the risks our key suppliers pose to provide us with an understanding of the Modern Slavery risks across our business

• included Modern Slavery risk assessments before we enter a relationship with a new supplier

• Provided Awareness Training

• Improved Compliance

• updated relevant existing legal contracts with suppliers and ensure Modern Slavery provisions are included in all new contracts

We will continue to build on our progress by keeping abreast of developments in the subject and learning from the oversight we conduct on our Third Parties.