Modern slavery statement

This Statement is made pursuant to s.54 of the UK Modern Slavery Act 2015 (the “Act”), and covers the business activities of Afiniti, Ltd. and its subsidiaries and affiliates (collectively, “Afiniti”, “we”, “our” or the “Company”). Afiniti, Ltd. is the parent company of Afiniti Europe Technologies Ltd., which is based in the United Kingdom.

Modern slavery can occur in various forms, including servitude, forced or compulsory labor, and human trafficking, all of which involve the deprivation of a person’s liberty by another to exploit them for personal or commercial gain. This Statement’s use of the term “modern slavery” has the meaning provided in the Act.

Our Commitment

We are committed to conducting our business ethically and transparently, and do not tolerate any form of modern slavery within our supply chain. Our Code of Conduct provides a clear set of standards for our conduct as an organization and for all employees globally. Employees receive a copy of Afiniti’s Code of Conduct at the start of their employment with the Company and are required to sign an annual declaration confirming they have understood and comply with its standards. Employees also receive periodic training to ensure the principles outlined in our Code of Conduct are an integral part of our culture. The Code of Conduct also outlines our expectations of our suppliers and vendors which are further enforced through our due diligence processes.

Due Diligence Processes

From time to time, Afiniti engages vendors and suppliers to purchase goods or services. We include anti-slavery clauses as part of our standard form contract for vendors and suppliers, requiring our vendors’ and suppliers’ commitment to preventing any form of slavery within their business or supply chain. As a practice, Afiniti also requests information from vendors and suppliers to confirm their compliance with the Act. While we cannot control the conduct of individuals or organizations in our supply chain, the following practical steps may be taken as necessary:

• Conduct risk assessments, as appropriate, to determine the parts of our business and the vendors or suppliers that
  would be most susceptible to risks of modern slavery.
• Include contractual provisions addressing modern slavery in contracts with our vendors and suppliers to promote
  their implementation of procedures to prevent modern slavery.
• Reserve the right to terminate contracts with vendors and suppliers at any time should any instances of modern
  slavery be identified.
• If any part of the business or any vendor or supplier faces a material risk of modern slavery, enhanced pre-screening,
  self-reporting requirements and additional training may be introduced.

Oversight

Our procurement team is trained to identify the signs of modern slavery and take action if it suspects that modern slavery is taking place in our supply chain. In accordance with our Code of Conduct, employees at all levels of the Company have a responsibility to report any known or suspected activity that could involve modern slavery. Afiniti employees are encouraged to familiarize themselves with our procedures to help in the identification and prevention of modern slavery and to conduct business in a manner that does not allow the occurrence of modern slavery.

Reporting Modern Slavery or Human Trafficking

We have a Reporting and Anti-Retaliation policy that provides guidance for all employees on how to raise concerns confidentially without fear of reprisal. Since September 2018, we have offered a whistle-blower hotline managed by an independent vendor to assist in employee reporting. Employees of Afiniti are expected to raise concerns at any time if they:

• Suspect that a person acting on behalf of the Company or on behalf of one of our vendors or suppliers is seeking to
  exploit another person in a way that could amount to modern slavery;
• Have been approached by someone acting on behalf of the Company who has invited them to participate in acts that
  could result in violations of the Act; or
• Believe in good faith that a person acting on behalf of the Company or one of its vendors or suppliers is preparing to
  commit, is committing, or has committed an act inconsistent with the requirements of the Act.

Third parties can also report concerns directly by emailing compliance@afiniti.com. Afiniti encourages anyone to report in good faith issues about potential ethical, legal, regulatory, or human rights violations. Once a report is received, Afiniti will promptly investigate it to the extent appropriate. Afiniti expects that all employees will cooperate in investigations fully and candidly. Corrective action will be taken, as appropriate, based on the findings of an investigation.

Safeguards

We promptly investigate any concern raised, as appropriate. If a concern involves an employee of a vendor or supplier, the vendor or supplier will be given time to investigate as necessary. If we make a reasonable conclusion that a violation has occurred there can be material consequences, which may include requiring the supplier to remediate the issue, disciplinary action up to termination of employment (for an employee of Afiniti), or termination of a contract (for a vendor or supplier).

Approval

This Statement has been approved by the Board of Directors of Afiniti Europe Technologies Ltd.

Hassan Afzal,
CEO, Afiniti, Ltd.

Last updated 2022