MODERN SLAVERY AND HUMAN TRAFFICKING

Document Ref:            KBCLUKPS0075
Version:                        2.0
Policy Owner:              Head of Compliance
Issue Date:                   09/09/2026
Review Date:               09/09/2027

Policy Statement

KBC Logistics Limited is committed to conducting its business ethically, responsibly and with integrity. We have a zero-tolerance approach to modern slavery, human trafficking, forced labour, servitude, child labour and any other form of exploitation within our own operations or supply chains.

We are committed to implementing appropriate systems and controls designed to prevent modern slavery and human trafficking and to identify and address potential risks.

Purpose

The purpose of this policy is to:

• Prevent modern slavery and human trafficking within KBC Logistics Limited and its supply chains.
• Establish clear expectations for employees, agency workers, contractors, subcontractors and suppliers.
• Provide a framework for identifying and reporting concerns.
• Ensure concerns are investigated and appropriately escalated.
• Support compliance with applicable UK legislation, including the Modern Slavery Act 2015.

Scope

This policy applies to all persons working for or on behalf of KBC Logistics Limited, including:

• Directors and senior managers.
• Employees.
• HGV drivers.
• Warehouse and operational personnel.
• Office employees.
• Agency workers.
• Temporary workers.
• Contractors and subcontractors.
• Labour providers.
• Consultants.
• Suppliers and other business partners.

Compliance with this policy is expected throughout our operations and supply chain.

What Is Modern Slavery?

Modern slavery is an umbrella term covering serious forms of exploitation where individuals are controlled, coerced or forced to work or provide services.

It may include:

Forced or compulsory labour – where individuals are forced to work through threats, intimidation, violence, debt or other forms of coercion.

Human trafficking – arranging or facilitating the movement of people for the purpose of exploitation.

Servitude – where an individual is forced to provide services and cannot freely leave.

Slavery – exercising powers of ownership or control over another person.

Child labour and exploitation – employment or exploitation of children contrary to applicable laws and internationally recognised standards.

Debt bondage – where individuals are forced to work to repay debts under exploitative conditions.

Our Commitment

KBC Logistics Limited will not knowingly conduct business with any organisation involved in slavery, forced labour, human trafficking or exploitation.

We expect our suppliers, contractors, subcontractors, labour providers and other business partners to maintain equivalent standards.

KBC Logistics Limited will take reasonable and proportionate steps to:

• Identify modern slavery risks.
• Assess higher-risk suppliers and labour arrangements.
• Conduct appropriate due diligence.
• Maintain appropriate recruitment controls.
• Investigate concerns.
• Take corrective action where necessary.
• Provide appropriate awareness and training.
• Review the effectiveness of our controls.

Recruitment and Employment

KBC Logistics Limited aims to ensure that workers are recruited legally, voluntarily and fairly.

The company will maintain appropriate processes for:

• Right to Work checks.
• Identity verification.
• Recruitment and onboarding.
• Agency and labour-provider approval.
• Employment documentation.
• Payment of wages.
• Working hours and rest.
• Reporting concerns.

Workers must not be required to surrender passports, identity documents or other personal documentation as a condition of employment, except where documents are temporarily required for a legitimate verification process and promptly returned.

Recruitment fees or arrangements that could result in workers becoming subject to debt bondage or exploitation will not be knowingly accepted.

Agency Workers and Labour Providers

Because temporary and agency labour can present increased risks of exploitation, KBC Logistics Limited will take reasonable steps to ensure labour providers operate lawfully and ethically.

This may include:

• Checking the legitimacy of labour providers.
• Confirming appropriate Right to Work controls.
• Reviewing contractual arrangements.
• Checking employment and payment arrangements where appropriate.
• Investigating unusual recruitment practices.
• Monitoring complaints and concerns.
• Requiring compliance with this policy.

Where appropriate, KBC Logistics Limited may require labour providers to provide evidence demonstrating their controls against modern slavery and worker exploitation.

Suppliers, Contractors and Subcontractors

Suppliers, contractors and subcontractors are expected to:

• Comply with applicable modern slavery legislation.
• Prohibit forced, trafficked and exploitative labour.
• Maintain appropriate employment and recruitment practices.
• Cooperate with reasonable due diligence requests.
• Report identified or suspected modern slavery within their operations or supply chains.
• Take corrective action where problems are identified.

Modern slavery considerations may form part of KBC Logistics Limited's supplier and contractor approval and review processes.

Serious or repeated non-compliance may result in suspension or termination of the business relationship, subject to appropriate investigation and consideration of the welfare of affected workers.

Transport and Logistics Risk

KBC Logistics Limited recognises that transport, logistics, warehousing, subcontracted haulage, temporary labour and international supply chains can present particular risks.

Managers should remain alert to potential exploitation involving:

• Agency drivers.
• Warehouse labour.
• Temporary workers.
• Subcontracted drivers.
• Vehicle cleaning and maintenance services.
• Security and cleaning contractors.
• Recruitment agencies.
• Overseas workers.
• Subcontracted transport operations.

Warning Signs

Possible indicators of exploitation may include an individual:

• Appearing frightened, withdrawn or controlled by another person.
• Being unable or unwilling to speak independently.
• Having another person control their identity documents.
• Having wages controlled or withheld.
• Being transported to and from work under unusual circumstances.
• Living in overcrowded or unsuitable accommodation.
• Appearing to have little control over their movements.
• Working excessive hours without appropriate rest.
• Showing signs of physical abuse, neglect or malnutrition.
• Being unable to explain their employment arrangements.
• Appearing to owe significant debts to recruiters or employers.
• Having employment terms significantly different from those originally promised.

The presence of one indicator does not automatically establish that modern slavery is taking place. Concerns should nevertheless be reported and appropriately assessed.

Employee Responsibilities

Everyone working for KBC Logistics Limited has a responsibility to support this policy.

Employees must:

• Comply with this policy.
• Remain alert to signs of exploitation.
• Report genuine concerns promptly.
• Cooperate with investigations.
• Never knowingly participate in or facilitate exploitation.

Managers have an additional responsibility to ensure concerns raised by workers are taken seriously and appropriately escalated.

Reporting Concerns

Anyone who suspects modern slavery, human trafficking or worker exploitation should report the concern as soon as possible to their:

Line Manager, Transport Manager, HR Department or Head of Compliance.

Where there is an immediate risk to someone's safety, the emergency services should be contacted.

Concerns should be handled sensitively and information shared only with those who need it for legitimate safeguarding, investigation or legal purposes.

Employees should not place themselves at risk or attempt to confront suspected traffickers or exploiters personally.

Whistleblowing and Protection

KBC Logistics Limited encourages employees and workers to raise genuine concerns without fear of retaliation.

Concerns may also be raised through the company's whistleblowing arrangements.

No person should suffer detrimental treatment for raising a genuine concern in good faith, even where an investigation subsequently finds that modern slavery has not occurred.

Knowingly making malicious or deliberately false allegations may, however, be dealt with under the company's disciplinary procedures.

Investigation and Escalation

Reported concerns will be assessed and, where appropriate, investigated.

Depending upon the circumstances, KBC Logistics Limited may:

• Protect or support affected individuals.
• Preserve relevant records and evidence.
• Escalate concerns to senior management.
• Seek specialist advice.
• Contact appropriate authorities.
• Review the relevant supplier, contractor or labour provider.
• Suspend activities where necessary to protect individuals.
• Implement corrective actions.
• Terminate commercial relationships where serious breaches are established.

The welfare and safety of potential victims will be considered when determining appropriate action.

Due Diligence

KBC Logistics Limited will apply proportionate due diligence according to the nature and level of risk.

This may include:

• Supplier questionnaires.
• Contractor approval checks.
• Labour-provider assessments.
• Contractual compliance requirements.
• Verification of recruitment practices.
• Review of policies and certifications.
• Risk-based audits.
• Investigation of complaints.
• Corrective-action plans.
• Periodic supplier reviews.

Higher-risk suppliers or labour arrangements may be subject to enhanced checks.

Training and Awareness

Relevant employees will receive appropriate information or training to help them:

• Understand modern slavery.
• Recognise potential warning signs.
• Understand recruitment and labour risks.
• Know how to report concerns.
• Understand their responsibilities under this policy.

Enhanced awareness may be provided to employees involved in procurement, recruitment, HR, compliance, transport management, supplier management and operational management.

Record Keeping and Monitoring

Appropriate records may be maintained relating to:

• Supplier and contractor assessments.
• Labour-provider checks.
• Modern slavery questionnaires.
• Training.
• Reported concerns.
• Investigations.
• Corrective actions.
• Supplier reviews.

The effectiveness of controls will be periodically reviewed.

Breaches of This Policy

Any employee found to have knowingly participated in, facilitated or concealed modern slavery or human trafficking may be subject to disciplinary action, up to and including dismissal.

Where a supplier, contractor, subcontractor or labour provider breaches this policy, KBC Logistics Limited may require corrective action, suspend the relationship or terminate the contract depending upon the seriousness of the circumstances.

Where appropriate, matters may also be reported to relevant authorities.

Modern Slavery Statement

Where KBC Logistics Limited is legally required to publish a slavery and human trafficking statement under the Modern Slavery Act 2015, the company will ensure that the statement is prepared, appropriately approved and published in accordance with applicable statutory requirements.

Where publication is not legally required, the company may nevertheless choose to publish a voluntary statement demonstrating its approach to preventing modern slavery.

Governance and Review

The Head of Compliance, supported by Senior Management, is responsible for coordinating implementation and periodic review of this policy.

This policy will normally be reviewed annually and sooner where there are:

• Significant legislative changes.
• Material changes to operations or supply chains.
• Serious incidents or allegations.
• Audit findings requiring revision.
• Significant changes to labour or subcontracting arrangements.