Human Trafficking and Forced Labour Policy

Company Statement:

Metway is committed to act with integrity in all our business dealings, to comply with all applicable laws and to act responsibly when dealing with our employees, customers, and suppliers or when interacting with communities. Recognising the suffering modern slavery and human trafficking cause, we have “zero tolerance” for any form of slavery or human trafficking in our operations and supply chain. We recognize that we have an on-going responsibility to ensure that appropriate measures are implemented to mitigate the risk of slavery and human trafficking in our operations, either directly or through our service providers. Pursuant to United Kingdom Modern Slavery Act of 2015 (Chapter 30, Part 6, Provision 54), Metway has established policies aimed at protecting individual human rights and freedoms and prohibiting forced labour and human trafficking in our supply chain and in our business operations.

Our Employees and Business:

Metway policy articulates our commitment to provide a work environment free from any form of harassment and unlawful discrimination, where every employee, customer, client, and third-party worker is treated with dignity and respect. Under the Metway Code of Conduct and Ethics, every eligible employee and manager of Metway is expected and required to assess every business decision and every action on behalf of the organization in light of whether it is right, legal and fair. Metway educates employees on relevant human rights issues through various communications and learning programs, including diversity and inclusion training. We view diversity and inclusion as a business imperative and our objective is to be an inclusive company; one that understands, honours and values the diversity of our customers, employees and the communities in which we live and work. We strive to create and nurture a unique and inclusive employee culture.

Our Suppliers:

Our commitment to human rights is also reflected in the suppliers we choose. Suppliers are expected to have guidelines, policies and practices that are communicated throughout their organization, upheld by all levels of management, and are considered and applied to their own supply chain activities. Metway extends its responsible procurement agenda further into the supply chain by applying enhanced due diligence to sourcing products and services when social, ethical, environmental and geographical factors suggest higher risk.

Suppliers are expected to have guidelines, policies, and practices that are communicated throughout the organization, upheld by all levels of management, and considered in and applied to their own supply chain activities.

These must address the following:

• Protection of Human Rights Respect for basic human rights, including rights to life and liberty, freedom of thought and expression, and equality.

• No tolerance for and protections against workplace harassment or abuse, violence, and discrimination (including for reasons of a person’s race, colour, sex, sexual orientation, gender identity, national origin, religion, veteran status, or disability).

• Environmental sustainability and a proactive management to ensure that applicable environmental standards are reflected in supplier operations and to minimize and mitigate environmental impacts.

• A culture of safety and supporting practices, minimizing risk of injury, illness, or death, and documented safety procedures (including accident reporting and emergency evacuation).

• Guidelines for workplace performance that define organisational expectations in respect of ethical, moral, and legal behaviours.

• Commitment within the workplace for diversity, including hiring and promoting based on merit and providing equal opportunity.

• Prohibition of conduct that could violate anti-bribery and/or anti-corruption laws.

• Compliance with applicable laws and regulatory requirements applicable to supplier and to goods and services being provided.

• Policies and practices that demonstrate a commitment to corporate responsibility for environmental, social, and ethical matters.

• Fair labour practices, with no tolerance for use of any form of child or forced labour, slavery, or human trafficking, in any operations or facilities; compliance with applicable labour laws including those relating to wage rates and conditions of employment Metway has found no instances or evidence of behaviours that would constitute the existence of modern slavery conditions in our supply chain.

18th November 2022

S Chessell

Steve Chessell, Managing Director