MODERN SLAVERY AND HUMAN TRAFFICKING POLICY 

SVEMA UK GROUP LIMITED 
February 2026 

1. Policy Statement 

SVEMA UK GROUP LIMITED is committed to conducting business ethically, transparently and with integrity. 
We maintain a zero-tolerance approach to modern slavery, forced labour, servitude and human trafficking in all aspects of our business and supply chain. 
We are committed to acting professionally, fairly and responsibly in all business relationships and to implementing effective systems and controls to safeguard against any form of modern slavery within our operations or supply chains. 

2. Scope

This policy applies to:

• Directors 
• Employees 
• Contractors and consultants 
• Agency workers 
• Suppliers and subcontractors 
• Business partners 
• It applies to all business activities undertaken by SVEMA UK GROUP LIMITED within the United Kingdom and in connection with its wider European supply chain. 

3. Definitions

Modern slavery includes:

• Slavery 
• Servitude 
• Forced or compulsory labour 
• Human trafficking 
• Child labour in breach of international labour standards 

4. Responsibilities

Directors

The Directors of SVEMA UK GROUP LIMITED have overall responsibility for ensuring this policy complies with legal and ethical obligations.

Management

Management is responsible for:

• Implementing this policy 
• Monitoring compliance 
• Ensuring appropriate supplier controls are in place 
• Addressing any concerns raised 

Employees and Workers

All employees and workers must:

• Read and understand this policy 
• Avoid any activity that might lead to a breach 
• Report concerns immediately 

  
5. Supplier and Supply Chain Standards

SVEMA UK GROUP LIMITED expects all suppliers and business partners to:

• Comply with applicable labour laws 
• Prohibit forced labour and human trafficking 
• Ensure employment is freely chosen 
• Provide safe working conditions 
• Pay fair wages in accordance with local laws 
• Allow workers freedom of association where legally permitted 

We reserve the right to:

• Conduct supplier due diligence 
• Request evidence of labour standards compliance 
• Include contractual obligations addressing modern slavery 
• Terminate relationships where serious breaches are identified

6. Due Diligence

We implement proportionate risk-based due diligence, which may include:

• Supplier onboarding assessments 
• Risk evaluation based on geography and sector 
• Review of supplier policies and certifications 
• Ongoing supplier engagement 
• Periodic compliance review

7. Reporting Concerns

SVEMA UK GROUP LIMITED encourages openness and will support anyone who raises genuine concerns in good faith. 
Concerns relating to modern slavery or unethical practices should be reported to:

• A Director 
• Line management 
• Through the Company’s Whistleblowing Policy 
• No individual will suffer detrimental treatment for raising concerns in good faith. 

8. Training and Awareness

Relevant personnel involved in procurement and supplier management receive awareness guidance on:

• Identifying modern slavery risks 
• Reporting procedures 
• Ethical sourcing responsibilities 

9. Breaches of this Policy

Any breach of this policy by employees may result in disciplinary action. 
Serious breaches by suppliers or partners may result in:

• Corrective action requirements 
• Suspension 
• Termination of contract 

10. Review

This policy will be reviewed periodically and updated as required to reflect legal or operational changes. 

Approved by: 
Director 
SVEMA UK GROUP LIMITED 
February 2026