Legal

Anti-slavery Policy

1. Purpose

Modern slavery is a crime and a violation of fundamental human rights. The purpose of this policy is to demonstrate our commitment to ethical business practices and respect for human rights. To ensure compliance with applicable legal and regulatory obligations and to provide guidance on identifying, reporting and responding to concerns relating to modern slavery.

2. References

• Modern Slavery Act 2015
• UK Government Transparency in Supply Chains Guidance
• Employment Rights Act 1996
• Public Interest Disclosure Act 1998
• Universal Declaration of Human Rights
• International Labour Organization (ILO) Forced Labour Conventions

3. Our commitment

DiffusionData has a zero-tolerance approach to modern slavery and human trafficking. We are committed to conducting business ethically, transparently and with integrity and to implementing effective systems and controls designed to prevent modern slavery within our operations and supply chains. Modern slavery can take a number of forms, including: slavery, servitude, forced or compulsory labour, human trafficking, debt bondage, child labour and exploitative labour practices. We expect that all individuals and suppliers that we do business with will hold their own suppliers to the same high standards.

4. Responsibilities

The senior leadership team has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

HR Manager and ISMS Manager are responsible for implementing and maintaining this policy. Monitoring compliance and reviewing the effectiveness of controls. Investigating any reported concerns. Coordinating policy reviews and updates and providing guidance as required.

Managers at all levels are responsible for ensuring that employees within their teams understand the requirements of this policy and comply with its provisions. They must raise concerns promptly when identified.

All employees and individuals working on behalf of DiffusionData are responsible for reading and complying with this policy. Remaining alert to signs of modern slavery and reporting any concerns promptly. All employees must Support investigations where required.

5. Supplier Due Diligence

DiffusionData recognises that supply chains can present modern slavery risks.

To manage these risks, we may undertake proportionate due diligence activities including supplier onboarding reviews, evaluation of supplier policies and standards. We may seek inclusion of contractual commitment regarding anti-slavery legislation. We may conduct periodic reviews.

Where concerns arise, suppliers may be required to implement corrective actions and provide evidence of remediation. Where serious breaches are identified and not adequately addressed, DiffusionData reserves the right to terminate the business relationship.

We expect our suppliers to apply similar standards throughout their own supply chains.

6. Compliance and Reporting Concerns

The prevention, detection and reporting of modern slavery is the responsibility of everyone working for or on behalf of DiffusionData.

Employees must not engage in any activity that may result in or suggest a breach of this policy.

Concerns may be raised through:

• A line manager.
• The HR Manager.
• A Director.
• The Company’s Whistleblowing Policy and reporting procedures.

Reports should be made as soon as reasonably possible when there is a concern or suspicion that modern slavery may be occurring.

Individuals who raise genuine concerns in good faith will be supported and protected from retaliation, victimisation or other detrimental treatment.

All reported concerns will be treated seriously and investigated appropriately.

7. Recognising the Signs of Modern Slavery

Indicators that may suggest modern slavery or labour exploitation include:

• Workers appearing fearful, anxious or withdrawn.
• Restricted freedom of movement.
• Individuals being controlled or supervised unusually closely.
• Confiscation of passports, identity documents or personal belongings.
• Unexplained wage deductions.
• Excessive recruitment fees or debt obligations.
• Poor living or working conditions.
• Lack of access to employment contracts or personal records.

This list is not exhaustive. Any concerns should be reported immediately.

8. Training and Awareness

DiffusionData will promote awareness of modern slavery through policy communications and management support.

All employees, contractors and temporary workers are expected to understand and comply with this policy.

9. Monitoring and Effectiveness

DiffusionData will monitor the effectiveness of its approach to combating modern slavery through:

• Completion of supplier due diligence activities.
• Review of supplier compliance concerns.
• Investigation outcomes relating to reported concerns.
• Employee awareness and training initiatives.
• Periodic assessment of modern slavery risks.
• Review of relevant legislation and industry best practice.

Findings from these activities will be used to improve our policies, processes and controls.

10. Breaches of this Policy

Any employee who breaches this policy may be subject to disciplinary action, up to and including dismissal for gross misconduct.