Human Trafficking & Modern Slavery Statement

Modified 26 June 2026

Introduction

This Human Trafficking and Modern Slavery Statement outlines the approach Strident takes to addressing human trafficking and modern slavery crimes.

Strident Ltd are committed to compliance with legal and regulatory requirements and makes this statement available to all working at the organisation and to interested parties via the company website.

Definition of Human Trafficking and Modern Slavery

Modern Slavery is the term used within the UK and is defined within the Modern Slavery Act 2015. The Act categorises offences of Slavery, Servitude and Forced or Compulsory Labour and Human Trafficking.

These crimes include holding a person in a position of slavery, servitude forced or compulsory labour, or facilitating their travel with the intention of exploiting them soon after. Although human trafficking often involves an international cross-border element, it is also possible to be a victim of modern slavery within your own country.

It is possible to be a victim even if consent has been given to be moved.

Children cannot give consent to being exploited therefore the element of coercion or deception does not need to be present to prove an offence.

There are several broad categories of exploitation linked to human trafficking, including:

• Sexual exploitation
• Forced or child labour
• Domestic servitude
• Organ harvesting
• Child related crimes such as child sexual exploitation, forced begging, illegal drug cultivation, organised theft, related benefit frauds etc
• Forced marriage and illegal adoption (if other constituent elements are present)

Policy

This policy applies to all persons working for the Company or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, and suppliers.

Strident Ltd strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. Strident Ltd have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains.

Our company expects everyone working with us or on our behalf of us to support and uphold the following measures to safeguard against modern slavery:

• The prevention, detection, and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf.
• Workers and suppliers must not engage in, facilitate, or fail to report any activity that might lead to, or suggest, a breach of this policy.
• We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
• We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach, we will also assess the merits of writing to suppliers requiring them to comply with our internal policies, which sets out the minimum standards required to combat modern slavery and trafficking.
• We provide our employees with training on the contents of this policy and how Strident use the policy to enforce good labour practices within the supply chain. Employees are also informed of the supplier assessment process and how modern slavery and human trafficking can be identified within the supply chain using the assessment and KPIs.
• Employees are provided with information on how to look out for the signs of human trafficking and modern slavery, including signs of physical violence, workers who are not able to move around freely, workers who appear to be under the control or fearful of someone else, workers who appear dishevelled or come to work in the same clothes each day, workers who appear to be isolated or are prohibited from leaving their place of work. Employees are encouraged to report any suspicions of such activities without delay to senior management – Strident ensure that workers who report suspicions are protected by the company whistle blowing policy.
• Ensuring that access to justice and remedy is available for victims of modern slavery.
• Consistent with our approach we require:
  • employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our internal policies, confirm their policies and require that they confirm any reports or investigations into modern slavery reports within the last years
  • that workers are hired on the basis of their skill and experience and that paid recruitment fees are forbidden by us and our suppliers
  • suppliers to complete assessments which include questions about modern slavery and human trafficking; suppliers are expected to provide evidence of their policies.
  • Strident ensure that supplier assessments are used to indicate the risk level the supplier presents in relation to modern slavery and human trafficking.
  • Suppliers shall be subject to a reassessment at least once every 3 years, dependant on their level of risk.
  • Suppliers to provide statements which detail their commitment to ensuring that they do not engage in debt bondage and do not work with suppliers who charge fees for employees to be hired or hold employees in debt to the company.

Strident have assessed its supply chain and countries of origin of all suppliers within our supply chain and have identified that only UK, EU and US suppliers are approved for use. These countries are low risk for modern slavery, therefore Strident have deemed the company and its supply chain as low risk regarding modern slavery and human trafficking risk. There are no high-risk areas within the supply chain.

Fair Labour

Strident is committed to ensuring that its workers have the freedoms afforded by fair labour and have used the Responsible Sourcing Tool (RST) to demonstrate that Strident's services are at low risk of slavery or forced labour within the supply chain. At a minimum Strident ensure:

• That workers are paid fairly and regularly, and to at least the national minimum wage
• That workers are free to terminate their employment as per the requirements of the employee handbook
• That workers are protected from discrimination, violence, harassment and intimidation and have implemented a Bullying and Harassment Policy to address this
• That compulsory overtime is prohibited
• That the company does not engage in child labour and will report any and all instances to the relevant authority
• That the company and its suppliers do not confiscate workers' identification documents

If we find that other individuals or organisations working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.

This Policy is signed by the Managing Director and is reviewed annually for suitability.