Human Trafficking and Anti-Slavery Policy

The Nycomm Group is committed to ensuring that it is free from acts of modern slavery from within its own business and within its supply chain. The Company acknowledges responsibility for implementing the requirements of the Modern Slavery Act 2015 and will ensure transparency within the organisation and with suppliers of goods and services to the organisation.

We expect the same high standards from those we work with and are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or any part of our business.

We have an approved supplier due diligence process which includes evaluating every new supplier before appointment. As part of this initial assessment process all suppliers are required to complete a questionnaire containing questions on their IT security, quality management system, corporate social responsibility and their supply chain. In particular, they are required to confirm that no slavery is used in their business and supply chain and that all necessary processes and policies have been put in place to ensure this remains the case.

Our standard contract also includes warranties that no slavery is used anywhere in the supplier’s business or by any of the suppliers in its supply chain. A contractual right to request compliance-related information and the right to audit supplier at our discretion is also in place. We expect our suppliers to respect human rights, including maintaining policies and procedures to prevent the use of child or forced labour.

The Company Directors and senior management will take responsibility for enhancing this policy statement and its objectives, and shall provide adequate training to ensure that, wherever possible, slavery and human trafficking is not taking place within the organization or within its supply chains.

C P Gee

Executive Director