MODERN SLAVERY AND HUMAN TRAFFICKING POLICY

Introduction:

Edouard Group Limited recognises that all businesses have an obligation to prevent slavery and human trafficking and since the implementation of the Modern Slavery Act 2015 we have undertaken a review of our policies and procedures to ensure we are delivering on our responsibilities in this regard. This statement sets out our commitment to preventing slavery and human trafficking in our business activities and the steps and policies we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small, and staff are expected to report their concerns and management are expected to act upon them.

Organisation structure, business and supply chains:

Edouard Group Limited is a service company offering rental of pressure testing equipment, Hydraulic hose & fitting sales and repair. The main business activities are principally undertaken in the UK and our supply chains comprise mainly UK based businesses. Our principal supply chains comprise sub-contractors who provide specialist goods and services to support our main business activities. Moving forward we will expect all employees and members of our supply chain to familiarise themselves with this policy which will be disseminated internally and which will be published on our website.

Our Policy in relation to slavery and human trafficking:

We do not permit or condone any form of modern slavery or human trafficking within our business or within our supply chain. We are committed to preventing any form of modern slavery and human trafficking and to ensuring that members of our supply chain are free from such activities. If we suspect or identify modern slavery or human trafficking within our supply chain we reserve the right to report such suspicions and to suspend or terminate our relationship with the supplier in question. We operate the following policies and practices across the business to help identify and minimise the risk of modern slavery or human trafficking occurring:

Supply chain:

Edouard Group Ltd Labour agencies: In response to the implementation of the Modern Slavery Act 2015, going forward we will seek written assurances from any organisation supplying agency labour regarding their practices to ensure slavery and human trafficking is not taking place within their business.

Edouard Group Ltd Sub-contractors: The appointment of sub-contractors involves an extensive and detailed pre-appointment process which amongst other things, requires written confirmation that sub-contractors will abide by and agree to the terms of this policy.

Own business:

• Equal Opportunities and Diversity Policy: This policy sets out the standards of behaviour and actions which all employees are expected to adhere to throughout the business. We seek to provide a work environment where employees are treated with respect, dignity and consideration.

• Corporate Social Responsibility Policy: This policy sets out how we work responsibly with all stakeholders in the business and how we demonstrate respect for staff, customers, suppliers, the community and the environment as a whole. • Anti-Bribery Policy: This policy sets out our zero-tolerance approach to bribery and corruption both within our business and our supply chain.

• Whistleblowing Policy: Our Whistleblowing policy encourages employees to report any concerns related to the activities of the business including any circumstances which may identify risks of modern slavery and human trafficking. The whistleblowing procedure is designed to make it easy for employees to make disclosures without fear of repercussions.

• Recruitment practices: We endeavour to carry out our own recruitment activities which involves carrying out appropriate background checks and ensuring the strict verification of an individual’s right to work in the UK.

• Pay practices: The rate of pay for our weekly paid operatives is governed by National Agreements which are strictly adhered to. All other employees are paid at rates above the national minimum wage and, where appropriate, the national living wage.

Due Diligence Processes:

As part of our commitment to ensuring that the risk of modern slavery or human trafficking within our supply chain is mitigated we will undertake the following due diligence procedures:

• New sub-contractors and labour agencies will be asked to supply copies of their Modern Slavery Statements (where they are required to prepare these) and/or to confirm compliance with our own policy.

• Any new members of our supply chain who are based outside the UK will be checked by reference to the Global Slavery Index at http://www.globalslaveryindex.org/findings/ to assess the status of the country in which they operate and to enable us to assess an appropriate risk level.

• Existing members of our supply chain will be monitored on an ongoing basis to confirm acceptance of and compliance with this policy.

Training and Awareness:

In order to raise awareness of the issue, we will communicate this policy and statement to all employees to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and in our business. All directors in the business have been briefed on the subject and we will provide training to relevant members of staff and in particular those responsible for recruiting and those responsible for engaging our supply chain.

Board Approval:

This statement has been approved by the Board of Directors, who will review it an update it annually.