MODERN SLAVERY STATEMENT

Introduction

Modern Slavery Act legislation prohibits slavery, servitude, forced or compulsory labour and human trafficking (collectively known as “Modern Slavery”). Modern Slavery is an international crime, affecting around an estimated 30 million slaves around the world and is a growing global issue that transcends age, gender and ethnicities. It includes victims brought from overseas and vulnerable people, forced to work illegally against their will across many different industry and service sectors.

RSD Vantage is committed to protecting and respecting human rights and has a zero-tolerance approach to Modern Slavery in all its forms. This statement is made according to Section 54, Part 6 of the UK Modern Slavery Act and sets out the steps taken concerning slavery and human trafficking during the financial year ending December 2020 and its general approach to the issue of Modern Slavery. RSD Vantage is headquartered in the UK. This Modern Slavery Statement applies to all of RSD Vantage operations and locations. The Managing Director, who will review and update it annually, has approved this statement.

Supply Chain and Adherence to Values

The majority of RSD Vantage relationships with members of the supply chain have been established over several years or are Client nominated. RSD Vantage has a supplier approval and evaluation process in place. As and when it has new contractors or suppliers come on board, it conducts due diligence on them through a series of checks which can include but not be limited to company performance, compliance — including HSEQ and references from other customers to establish suitability. To date, RSD Vantage is not aware of any human trafficking/slavery activities within its supply chain but if any were highlighted to it then it would act immediately under its legal and moral obligations.

Due to the nature of its business and supplies, as well as RSD Vantage’s approach to governance, it considers the risk of Modern Slavery to be very low however, it continues to review periodically the effectiveness of the relevant policies and procedures that it has in place.

Company’s Policies and Procedures

RSD Vantage operates several internal policies to ensure that it is conducting business ethically and transparently. These include:

• Business Ethics & Conduct Policy: the code makes it clear to employees the actions and behaviour expected of them when representing the organisation. RSD Vantage strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain. The code also describes how it expects those with whom it does business, including the supply chain, to behave.

• Recruitment Policy: RSD Vantage operates a robust recruitment policy, including conducting checks on eligibility to work for all employees, to safeguard against human trafficking or individuals being forced to work against their will.

• Whistleblowing Policy: RSD Vantage encourages all employees, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of Modern Slavery. The Whistleblowing Policy is designed to make it easy for workers to make disclosures, without fear of reprisals.