Document controlled by: [Director / Board]
Approved date: [01/05/2025]
Next review date: [01/05/2026]

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1. Purpose

Performance Goal C.I.C (“the Company”) is committed to conducting its business ethically and in compliance with the Modern Slavery Act 2015 and related human rights standards. This policy is intended to:

• Prevent modern slavery, human trafficking, forced labour, and servitude within our operations and supply chains;

• Set out the responsibilities of the Company, its management, employees, suppliers and contractors for ensuring this is not occurring;

• Provide transparency about the actions we take to mitigate slavery risks;

• Support detection, reporting and remediation of any issues that may arise.

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2. Scope

This policy applies to:

• All employees, temporary staff, contractors, and agency workers of Performance Goal C.I.C;

• All operations carried out in the UK, and in any other jurisdiction where we operate;

• All parts of our supply chain, including direct suppliers, subcontractors, service providers, and partners;

• All goods and services procured by the Company.

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3. Definitions

• Modern slavery includes (but is not limited to) slavery, human trafficking, forced or compulsory labour, servitude, debt bondage.

• Supplier refers to any organisation or individual that provides goods or services to Performance Goal C.I.C.

• Vulnerable worker refers to workers who may be at greater risk of exploitation (e.g. migrant workers, workers with irregular status, low-paid roles, agency/seasonal workers).

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4. Our Commitments

Performance Goal C.I.C commits to:

• Comply with all applicable laws, regulations and codes relating to modern slavery, both in the UK and abroad;

• Ensure that our own operations are free from modern slavery and exploitative practices;

• Conduct due diligence on our suppliers and third parties to assess risks of modern slavery;

• Include anti-slavery clauses in contracts with suppliers, contractors and partners;

• Provide training for relevant employees (procurement, HR, operations) to raise awareness;

• Encourage reporting of concerns; ensure that there are channels for anonymous or confidential reporting;

• Investigate any reports of alleged slavery or trafficking thoroughly, promptly, and where needed, work to remediate harm;

• Monitor and review this policy and effectiveness of our actions regularly.

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5. Risk Assessment and Due Diligence

To identify, assess, and manage risks of modern slavery we will:

• Maintain a map of our supply chain including high-risk countries, sectors, and parts of operations;

• Require suppliers to provide information on their labour practices, employment terms, worker rights, recruitment methods, subcontracting;

• Prioritise audits, site visits, or third-party verification for suppliers in high-risk categories;

• Review supplier policies, certifications, audits, and reports where available;

• Use Key Performance Indicators (KPIs) to track supplier compliance and improvements.

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6. Supplier & Contractual Controls

To enforce compliance we will:

• Include anti-slavery and human trafficking clauses in supplier contracts (e.g. prohibitions of forced labour, rights of audit, termination in case of breach);

• Require suppliers to ensure similar responsibilities flow down their chains (i.e. subcontractors);

• Withhold payments or suspend contracts if there is evidence of serious non-compliance until remedial action is taken;

• Provide support / guidance to suppliers to help them understand expectations and to improve where needed.

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7. Employee Responsibilities

• Employees must be familiar with this policy and make themselves aware of how to detect and report issues of modern slavery;

• Management should ensure staff under their supervision are aware and trained;

• HR must ensure legal and fair recruitment, confirm identities, ensure that there is no charging of recruitment fees to workers, ensure workers retain control of their identity documents;

• Procurement should integrate risk‐based supplier selection and monitoring.

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8. Reporting

• Any worker, supplier or stakeholder who suspects or becomes aware of modern slavery or trafficking in our operations or supply chains must report via [internal reporting channel/whistleblowing policy];

• Reports will be treated seriously, investigated promptly and confidentially;

• We will protect whistleblowers from retaliation;

• External incidents may also be reported to appropriate authorities (e.g. UK law enforcement, the Modern Slavery Helpline).

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9. Training & Awareness

• Regular training for staff in procurement, operations, HR, and senior leadership on modern slavery risks, detection, and this policy;

• Include modern slavery awareness in employee induction;

• Provide suppliers with guidance or training where feasible;

• Keep up to date with emerging risks, legislation changes, best practice.

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10. Monitoring, Review & KPIs

We will monitor and measure the effectiveness of this policy by:

The Board / Senior Management will receive periodic updates on these measures.

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11. Governance and Responsibility

• The Board / Directors have overall responsibility for ensuring this policy is implemented and effective;

• A designated officer (e.g. Head of Compliance or equivalent) shall be responsible for implementing this policy on a day-to-day basis;

• Department heads (HR, Procurement, Operations) are responsible for embedding the policy in their functions;

• All staff have responsibility for compliance with the policy.

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12. Consequences of Non-Compliance

• Breach of this policy may lead to disciplinary action (for employees);

• Suppliers or contractors found in breach may face contract termination, suspension, or other remedies;

• The Company may take legal or other actions if required.