MODERN SLAVERY (ANTI SLAVERY AND HUMAN TRAFFICKING) POLICY

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

Vectaire Ltd has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its own business or in any supply chains.

Vectaire Ltd is also committed to ensuring there is transparency in its own business and in its approach to tackling modern slavery throughout its supply chains, consistent with disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

SCOPE/TO WHOM THIS POLICY APPLIES

This policy applies to all persons working for Vectaire Ltd or on its behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

This policy does not form part of any employee's contract of employment and Vectaire Ltd may amend it at any time.

RELATED POLICIES and PROCEDURES

This Modern Slavery (Anti-Slavery and Human Trafficking) Policy interacts with the following workplace policies and procedures. You are encouraged to familiarise yourself with the policies detailed below.

• Whistleblowing policy

Responsibility for policy - Vectaire Ltd has overall responsibility for ensuring this policy with senior management; and managers have day to day responsibility to ensure compliance with legal and ethical obligations.

The Managing Director has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Managers at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

• Compliance with this policy - all employees MUST read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. Staff are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Managers must be notified as soon as possible if there is a belief or suspicion that a conflict with this policy has occurred, or may occur in the future, or a report may be made in accordance with the Whistleblowing Policy

Staff are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

If a member of staff is unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, a manager must be informed.

Vectaire Ltd aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

Vectaire Ltd is committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith a suspicion that modern slavery of whatever form is, or may be taking place, in any part of its own business or in any of its supply chains.

Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If a member of staff believes that they have suffered any such treatment, a manager should be informed immediately. If the matter is not remedied the member of staff should raise it formally using the Grievance Procedure from the HR department.

Communication and awareness of this policy - training on this policy, and on the risk Vectaire Ltd's business faces from modern slavery in its supply chains, will be provided as necessary.

Vectaire Ltd's zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Breaches of this policy - any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

Vectaire Ltd may terminate its relationship with other individuals and organisations working on its behalf if they breach this policy.