Modern slavery Modern Slavery and Human Trafficking Statement 2021 Axistwelve is committed to combatting modern slavery, servitude, forced or compulsory labour and human trafficking in every part of its business and supply chains. This statement sets out Axistwelve's approach by describing the policy framework, due diligence and monitoring implemented to prevent all forms of modern slavery. Our Approach Axistwelve's Business Code of Practice states our commitment to embedding high ethical standards throughout the business and to operating, as a minimum, in accordance with all applicable laws and regulations. We apply these high standards to our engagement with stakeholders, our approach to managing our environmental impacts, the quality of services and facilities we supply, our employment practices, procurement and corporate reporting. As outlined in our Financial Crime Policy, we take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings. We expect those who work with or for Axistwelve to comply with their tax obligations. Axistwelve employees are expected to deliver their roles with integrity, following ethical business practices in line with Axistwelve's approach to high standards of personal and professional ethics. This includes awareness of the risk of breaches of human rights, including modern slavery, forced labour and human trafficking. A range of HR policies and procedures support the recruitment and management of employees in a fair and positive manner. The policies also protect our employees and their labour rights in our operations. We operate a Whistleblowing Policy and independent Whistleblowing hotline to encourage staff, and those affiliated with the business, to report any suspected wrongdoing, in the knowledge that their concerns will be taken seriously and investigated in confidence. We have not received any modern slavery related complaints or allegations of serious labour abuse during the financial year ended 31 December 2021. Our Employees We have policies and procedures in place to protect our directly employed employees and their labour rights. We have ensured that applicable policies and procedures remained effective and appropriate during 2020, when our employees predominantly worked remotely due to the COVID-19 pandemic. All employees are paid above the London Living wage. We also ensure that the providers of managed services to our offices and estates pay the London Living Wage to those working with Axistwelve. We believe that as we are a UK employer that is subject to UK employment legislation and as we have well developed internal controls within our business there continues to be a minimal risk of modern slavery incidences relating to the recruitment and management of Axistwelve's directly employed employees. Our Suppliers As a digital company that designs, builds, hosts and support digital assets, we procure a wide range of goods, services and works to support the delivery of our business strategy. Axistwelve considers that the highest potential risk areas in relation to modern slavery are in its supply chain. To mitigate the risks that could be associated with our business and our supply chain, Axistwelve has put in place policies, procedures and processes to avoid incidences of modern slavery and human trafficking. Axistwelve has a Procurement Policy and procedure to support employees in achieving best value and minimising risk when procuring goods, services and works. This is supported by a Supply Chain Policy which sets out the ethical standards we require our suppliers to uphold and specifically addresses modern slavery and human trafficking. Should we believe that a supplier is not undertaking adequate action to prevent modern slavery or human trafficking, or is practising in breach of Axistwelve's policies or legislation, then the relationship with the supplier would be terminated. Training On joining Axistwelve all permanent and fixed term contract employees are made aware of modern slavery and human trafficking as part of the formal induction process. All employees are made aware of our policies and procedures including those on financial crime, whistleblowing, diversity and inclusion, health and safety and anti-bullying and harassment and are periodically required to review and confirm their understanding of company policies. Bespoke training on modern slavery and human trafficking will continue to be provided to relevant employees and included as part of the formal induction process for new employees. Evaluating Performance Whilst we believe that the risk of modern slavery within our direct operations is low, we recognise the need to set best practice standards for our supply chain and to regularly monitor and evaluate their performance. We remain committed to demonstrating strong environmental, social and governance practices. In the year ahead we will continue to raise the awareness of modern slavery to our employees, engage with and review supplier performance.