Modern Slavery Policy

Introduction
Nicholas Alexander ("the Company") is committed to preventing modern slavery and human trafficking in all aspects of our business operations and supply chains. We recognise the importance of acting ethically and with integrity, and we are dedicated to ensuring that our business practices do not contribute to modern slavery in any form. This policy outlines our approach to identifying, preventing, and addressing modern slavery and human trafficking risks, in compliance with the UK Modern Slavery Act 2015 and other applicable international laws.

Purpose
This policy sets out Nicholas Alexander’s stance on modern slavery and human trafficking, detailing our commitment to transparency, ethical practices, and human rights. It applies to all employees, contractors, suppliers, and partners involved in our business operations globally.

Our Commitment

We are committed to:

Conducting business in a manner that respects the rights and dignity of all individuals.
Ensuring that modern slavery, including forced labour, bonded labour, and human trafficking, has no place in our operations or supply chains.
Complying with all relevant laws and regulations, including the UK Modern Slavery Act 2015, the US Trafficking Victims Protection Act, the EU Directive on Human Trafficking, and other international human rights standards.
Implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in our business or in any of our supply chains.

Scope
This policy applies to:

All employees, contractors, suppliers, and business partners, regardless of their location.
All aspects of Nicholas Alexander’s operations, including sourcing, procurement, and service delivery.

Due Diligence and Risk Assessment

We conduct regular due diligence to identify, prevent, and mitigate the risks of modern slavery and human trafficking within our business and supply chains. This includes:

Assessing the risk of modern slavery in our operations and supply chains, particularly in high-risk regions and sectors.
Requiring all suppliers and partners to adhere to our Supplier Code of Conduct, which includes provisions on labor rights and anti-slavery practices.
Implementing monitoring and auditing processes to ensure compliance with our policies and standards.
Taking immediate corrective action if any instances of non-compliance are identified.

Training and Awareness

We provide regular training to all employees on the risks of modern slavery and human trafficking, as well as on the steps that can be taken to prevent it. This training includes:

Raising awareness of the signs of modern slavery and how to report concerns.
Educating employees on the legal and ethical obligations under the UK Modern Slavery Act 2015 and other relevant legislation.
Ensuring that all employees understand Nicholas Alexander’s commitment to combating modern slavery and their role in supporting this effort.

Reporting Concerns

Nicholas Alexander encourages all employees, contractors, and partners to report any concerns related to modern slavery or human trafficking. Reports can be made confidentially and without fear of retaliation through confidential email to whistleblowing@nicholasalexander.global. All reports will be thoroughly investigated, and appropriate action will be taken.

Continuous Improvement

We are committed to continuously improving our practices to combat modern slavery and human trafficking. This includes:

Regularly reviewing and updating this policy to reflect changes in laws, regulations, and best practices.
Engaging with stakeholders, including suppliers, partners, and industry groups, to share knowledge and improve our approach to preventing modern slavery.
Reporting on our efforts and progress in our annual Modern Slavery Statement.

Governance

The responsibility for implementing and monitoring this policy lies with Human Resources. The CEO has overall accountability for ensuring compliance with this policy and for providing updates to the Board of Directors on our progress.

Conclusion
Nicholas Alexander is dedicated to ensuring that modern slavery and human trafficking have no place in our business or supply chains. We will continue to uphold our commitment to ethical business practices and work towards a future where all individuals are treated with dignity and respect.