1 POLICY STATEMENT

1.1 This is the anti-slavery policy of CP Plus Limited (trading as GroupNexus) and all UK entities
that form part of the same group or are otherwise affiliated or associated from time to time –
hereinafter collectively referred to as “GroupNexus” (and “we”, “us” and “our”).
1.2 Modern slavery is a crime and a violation of fundamental human rights. GroupNexus
recognises that this 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.
1.3 GroupNexus is committed to acting ethically and with integrity in all its business dealings and
relationships and implementing and enforcing effective systems and controls to ensure
modern slavery is not taking place anywhere in its business operations or in any of
GroupNexus’s supply chains.
1.4 GroupNexus is also committed to ensuring there is transparency in its business and in its
approach to tackling modern slavery throughout its supply chains, consistent with its
disclosure obligations under the Modern Slavery Act 2015 (the “Act”). It expects the same
high standards from all of its suppliers, contractors and other business partners. As part of
GroupNexus’s contracting processes, it expects that its suppliers will hold their own suppliers
to the same standards set out in this policy.

 

2. ABOUT THIS POLICY

2.1 The purpose of this policy is to:

• set out our responsibilities, and of those working for and on our behalf, in observing and
  upholding our position on modern slavery and human trafficking; and
• provide information to those working for and on our behalf on how to identify and report
  concerns regarding modern slavery and human trafficking.

2.2 This policy applies to all persons working for GroupNexus or on its behalf in any capacity,
including employees at all levels, directors, officers, frontline staff, agency workers (including
those engaged by suppliers), volunteers, interns, agents, suppliers, contractors, external
consultants, third-party representatives and business partners (collectively, “Associated
Persons”).
2.3 The board of directors of each relevant GroupNexus entity has overall responsibility for
ensuring this policy complies with GroupNexus’s legal and ethical obligations, and that all
those under its control comply with it.
2.4 All GroupNexus managers are responsible for ensuring that this policy and GroupNexus’s zero-
tolerance approach to modern slavery is communicated to all employees and for ensuring
those individuals reporting to them understand and comply with this policy and are given
adequate and regular training as applicable on the policy and the issue of modern slavery in
supply chains.
2.5 Management has 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.
2.6 We may amend this policy from time to time.

3. COMPLIANCE WITH THE POLICY

3.1 All Associated Persons must comply with this policy and are required to avoid any activity that
might lead to, or suggest, a breach of this policy.
3.2 All Associated Persons are required to raise any concerns about any issue or suspicion of
modern slavery in any part of GroupNexus’s business or supply chains of any supplier tier at
the earliest possible stage.
3.3 GroupNexus 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. GroupNexus is
committed to ensuring no one suffers any detrimental treatment as a result of reporting in
good faith their suspicion that modern slavery of whatever form is or may be taking place in
any part of the business or in any of GroupNexus’s supply chains. “Detrimental treatment”
includes dismissal, disciplinary action, threats or other unfavourable treatment connected with
raising a concern.
3.4 If any GroupNexus staff member believe they have suffered any detrimental treatment
referred to at paragraph 3.3 , the individual should inform either their manager or the HR
Department without delay. If the matter is not remedied, the GroupNexus staff member
should raise it formally in accordance with the grievance procedure, which can be found in the
GroupNexus employee handbook.
3.5 As part of our due diligence process, all suppliers/sub-contractors must complete a
questionnaire relating to quality control (covering the commitment under this policy) and their
suitability as supplier/sub-contractor of GroupNexus is assessed based on this questionnaire
prior to award of contract. Where GroupNexus (acting reasonably) considers it necessary, a
GroupNexus representative may visit a supplier/sub-contractor to ensure that it is completely
satisfied with the processes and procedures in place and in accordance with the supplier/sub-
contractor’s policy. Those responsible for setting up contracts with suppliers/sub-contractors
are to utilise the questionnaire and forward onto GroupNexus’s designated manager of the
Approved Supplier/Sub-contractor Register who will be responsible for assessing the
suppliers/sub-contractors annually for their commitment to its policies.
3.6 GroupNexus may from time to time require suppliers/sub-contractors to execute a letter in
the form prescribed in Annex A to this policy, particularly in the following circumstances:

• where the supplier/sub-contractor has not completed the questionnaire mentioned at
  paragraph 3.5 ;
• where the supplier/subcontractor has completed the questionnaire, but the responses to
  the questionnaire are deemed unsatisfactory to GroupNexus;
• where the contract between GroupNexus and the supplier/sub-contractor does not
  include an obligation to comply with the Act; an
• where GroupNexus considers that the anti-slavery provisions in its contract with the
  supplier/sub-contractor are inadequate.

4. REPORTING CONCERNS

4.1 Reporting concerns about modern slavery is a vital step in protecting vulnerable individuals
and upholding ethical and legal standards within our organisation and wider society. As
mentioned at paragraph 1.2 , modern slavery can take many forms and often goes unnoticed
without the vigilance and courage of those who speak up.
4.2 By reporting suspected cases, Associated Persons help ensure that:

• individuals at risk are identified and supported;
• the organisation remains compliant with the Act and related ethical obligations;
• unsafe or exploitative practices are stopped before further harm occurs; and
• a culture of integrity, transparency and accountability is maintained.

 

4.3 If any Associated Person has any reason to believe or suspect that a breach of this policy has
occurred or that it may occur, they are required to, as soon as reasonably practicable:

• If they are a GroupNexus staff member:
  (i) notify either their line manager or the HR department; or
  (ii) report their concerns through the whistle-blowing procedure set out in the
  GroupNexus employee handbook;
• If they are any other Associated Persons: notify a senior GroupNexus manager, who may
  escalate the matter to the Operations Director where appropriate

4.4 If any Associated Person is unsure about whether any particular act, treatment of workers
more generally, or their working conditions within any tier of GroupNexus’s supply chains
constitutes a form of modern slavery, this should still be raised in accordance with paragraph
4.3 .
4.5 In addition to the reporting mechanisms outlined in paragraph 4.3 , Associated Persons can
also raise concerns confidentially by contacting the Modern Slavery Helpline on 0800 0121 700
or at www.modernslaveryhelpline.org. However, Associated Persons are encouraged to
conduct initial reporting pursuant to paragraph 4.3 .
4.6 All reports are taken seriously and investigated promptly, with appropriate action taken to
address any issues identified. Speaking up plays a crucial role in ensuring that our workplace
and supply chains remain free from modern slavery and exploitation.

5. TRAINING AND COMMUNICATION

5.1 Training on this policy, and on the risk our business faces from modern slavery in its supply
chains, forms part of the induction process for all individuals who work for us, and refresher training will be provided as necessary. GroupNexus line managers are responsible for ensuring
that all employees have completed any such training.
5.2 All GroupNexus contract managers and heads of departments who are responsible for
procurement of goods and/or services must ensure that this policy and GroupNexus’s zero-
tolerance approach to modern slavery is communicated to all suppliers, contractors and
business partners during the procurement process and/or at the outset of each business
relationship, and reinforced as appropriate on an ongoing basis.
5.3 All contract managers and heads of departments are also responsible for ensuring that
adequate safeguards are implemented when engaging or contracting with third parties. Such
safeguards may include incorporating contractual obligations to comply with the Act or
requiring the execution of a compliance letter, as appropriate.

6 BREACHES OF THIS POLICY

6.1 Any employee who breaches this policy will face disciplinary action, which could result in
dismissal for misconduct or gross misconduct.
6.2 We may terminate our relationship with suppliers, contractors or other business partners if
they breach this policy.

Signed: Ian Langdon
Appointment: Operations Director
Date: 14.03.26

Annex A
Template compliance letter

[NAME OF SUPPLIER]
[ADDRESS LINE 1]
[ADDRESS LINE 2]

Dear Sir/Madam
Modern Slavery Act 2015 (the “Act”)
We refer to the agreement between you and us for [DESCRIPTION OF AGREEMENT] dated [DATE]
[and amended on [DATE(S)]] OR as amended from time to time] (the “Agreement”), a copy of which
is annexed to this letter.
We have a zero-tolerance approach to modern slavery, which is a crime and a violation of
fundamental human rights. We recognise this 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. We are
committed to acting ethically and with integrity in all our business dealings and relationships with
suppliers.

The purpose of this letter is to supplement the Agreement with the terms set out below relating to
compliance with the Act.
In performing your obligations under the Agreement, you agree:

• to comply with (and procure that your own suppliers, sub-contractors and other participants
  in your supply chains comply with) the Act and the GroupNexus Anti-Slavery Policy (as
  amended from time to time and available upon request);
•  to implement appropriate due diligence procedures for your own suppliers, sub-contractors
  and other participants in your supply chains to ensure that there is no slavery or human
  trafficking;
• to notify us and confirm the same promptly in writing immediately upon discovering any
  breach or potential breach of the Act or any actual or suspected slavery or human trafficking
  in your supply chains; and that a breach of the terms of this letter shall entitle use to terminate the Agreement with
  immediate effect upon notice.

The parties intend this letter to be legally binding.
To the extent of any conflict between the terms of the Agreement and this letter, the terms of this
letter shall prevail.

This letter and any dispute or claim (including non-contractual disputes or claims) arising out of or in
connection with it or its subject matter or formation shall be governed by and construed in
accordance with the law of England and Wales.

Each party irrevocably agrees that the courts of England and Wales shall have exclusive jurisdiction to
settle any dispute or claim (including non-contractual disputes or claims) arising out of or in
connection with this letter or its subject matter or formation.

Please acknowledge receipt and acceptance of this letter by signing, dating and returning a copy of
this letter. This letter has been executed as a deed and is delivered and takes effect on the date of the signature
of the last signatory.

Executed as a deed by CP PLUS LIMITED acting by the following authorised signatories:

…………………………………………..
[NAME OF FIRST DIRECTOR]
Director

Date: ………………………………….

…………………………………………..
[NAME OF SECOND DIRECTOR]
Director
Date: ………………………………….

We acknowledge receipt and accept the contents of this letter.
[Executed as a deed by [NAME OF SUPPLIER] acting by the following authorised signatories:

…………………………………………..
[NAME OF FIRST DIRECTOR]
Director
Date: ………………………………….

…………………………………………..
[NAME OF SECOND DIRECTOR]
Director
Date: ………………………………….]

OR
[Executed as a deed by [NAME OF SUPPLIER] acting by:

…………………………………………..
[NAME OF DIRECTOR]
Director
Date: ………………………………….

In the presence of:
Signature of witness: …………………………………………..
Name of witness: …………………………………………..
Address of witness: …………………………………………..
Occupation of witness: …………………………………………..]