Modern Slavery

Harlow Stewart Limited (“we,” “us,” or “our”) is fully committed to preventing modern slavery and human trafficking in all aspects of our business operations and supply chains. We recognize our responsibility to act ethically and with integrity, ensuring that modern slavery is not present in our own business or in the businesses of our suppliers and partners. This policy outlines our commitment to combating modern slavery and our approach to ensuring compliance with the UK Modern Slavery Act 2015.

1. Our Commitment

We are committed to ensuring that there is no modern slavery or human trafficking in our operations or supply chains. This commitment is underpinned by our dedication to upholding human rights and promoting ethical business practices throughout our organization.

2. Our Business and Supply Chains

As a small company with limited suppliers and partners, we recognize the importance of understanding and managing the risks of modern slavery within our business and supply chains. We take steps to ensure that our suppliers and partners share our commitment to preventing modern slavery and human trafficking.

3. Risk Assessment and Due Diligence

• Risk Assessment: We assess the risk of modern slavery and human trafficking in our operations and supply chains. This includes evaluating the nature of our business relationships and the geographical locations of our suppliers.
• Due Diligence: We conduct due diligence on our suppliers to ensure they adhere to ethical labor practices. This process includes reviewing their policies, practices, and any relevant certifications to confirm their commitment to combating modern slavery.

4. Supplier Code of Conduct

We expect all our suppliers and partners to operate in full compliance with the UK Modern Slavery Act 2015 and to uphold high standards of ethics and integrity. Our Supplier Code of Conduct outlines our expectations, including:

• Prohibition of Forced Labor: Suppliers must ensure that all work is voluntary and that no one is subjected to forced, bonded, or involuntary labor.
• Fair Treatment: Suppliers must treat all workers with respect and dignity, ensuring fair wages, reasonable working hours, and safe working conditions.
• Prevention of Child Labor: Suppliers must adhere to the minimum legal working age and must not engage in or support child labor.

5. Training and Awareness

We are committed to raising awareness about modern slavery and human trafficking among our employees. We will provide training to help our staff identify the signs of modern slavery and understand how to report concerns. This training is particularly focused on those who are responsible for procurement and supplier management.

6. Reporting and Whistleblowing

We encourage anyone who suspects that modern slavery or human trafficking may be present in our operations or supply chains to report their concerns immediately. We provide a confidential and secure process for reporting such concerns, and we ensure that whistleblowers are protected from retaliation.

7. Monitoring and Review

We regularly monitor our business practices and supply chains to ensure ongoing compliance with this policy and the UK Modern Slavery Act 2015. This policy will be reviewed annually or as needed to ensure it remains effective and up to date.

Conclusion

Harlow Stewart Limited is committed to acting with integrity in all our business dealings. By working together with our employees, suppliers, and partners, we aim to prevent modern slavery and human trafficking in any form. Any questions or concerns regarding this policy should be directed to the Directors.