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��ɫ��Ƶ Modern Slavery and Human Trafficking Statement 2023/24

��ɫ��Ƶ Holdings plc and its subsidiaries (“��ɫ��Ƶ”) are committed to understanding modern slavery risks and ensuring that our businesses and supply chain are free from modern slavery and human trafficking. This statement (made pursuant to section 54 of the Modern Slavery Act 2015 (the “Act”)) sets out the steps that ��ɫ��Ƶ has taken during the financial year ended 30 September 2024 (“FY24”) and will continue to take to meet this commitment. We review this statement annually and this statement was approved by the Board on 4 November 2024. 

Like all businesses we run the risk of modern slavery within our operations including our supply chain. Due to the nature of our business, we feel that we carry a limited risk of modern slavery compared to other industries. However, we recognise our ongoing responsibility in managing our business and supply chains responsibly, to mitigate and where necessary remediate, the risks of modern slavery. 

There were no concerns or instances relating to modern slavery raised to us through our due diligence processes during FY24.

Business and organizational structure 

��ɫ��Ƶ is a unique, world-leading provider of technology-enabled language, content and intellectual property services. Through content transformation and multilingual data analysis, our unique combination of technology and cultural expertise helps our clients to grow by ensuring they are understood anywhere, in any language. 

Our purpose is unlocking global understanding. By combining cultural understanding, client understanding and technical understanding, our services and technology assist our clients to acquire and retain customers, deliver engaging user experiences, maintain compliance and gain actionable insights into their data and content. 

We work with over 80% of the world's top 100 brands, more than three-quarters of Fortune's 20 'Most Admired Companies' and almost all of the top pharmaceutical companies, investment banks, law firms and patent filers. Our client base spans Europe, Asia Pacific, Africa and North and South America. Our 65+ global locations across five continents service clients in the automotive, chemical, financial, legal, medical, pharmaceutical, technology and telecommunications sectors. 

Founded in 1958, ��ɫ��Ƶ is headquartered in the UK and publicly listed on AIM, the London Stock Exchange regulated market (��ɫ��Ƶ.L).

Policies and supply chain 

��ɫ��Ƶ has a number of policies and procedures designed to ensure that its activities, and those of its suppliers, are conducted ethically and in accordance with all applicable laws. These include the Modern Slavery and Human Trafficking policy, our Code of Conduct and policies and procedures relating to procurement and speaking-up. 

��ɫ��Ƶ has reviewed its supply chain to identify areas that may pose a higher risk of modern slavery and human trafficking. ��ɫ��Ƶ’s key suppliers are entities or individuals providing professional services, primarily freelance translators, who support ��ɫ��Ƶ’s client-facing activities, as well as a range of suppliers providing other services to support the operation of ��ɫ��Ƶ. We therefore believe that ��ɫ��Ƶ’s supply chain continues to pose a lower risk of slavery and human trafficking than that of companies operating in other sectors; however, some risk does exist, and ��ɫ��Ƶ is committed to mitigating that risk. By way of example, our programme for onboarding freelance translators includes background and identity checks, mandated adherence to our Supplier Code of Conduct, training and ongoing monitoring.

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��ɫ��Ƶ’s commitment to compliance with the Act applies equally to its own employees. Through its selection, recruitment and onboarding processes, ��ɫ��Ƶ aims to ensure that the people it employs are not subject to modern slavery and human trafficking and are afforded the rights and protections that they are entitled to by law. 

We also implement training programmes to raise awareness of ethical risks. To support full understanding and effective use of the Code of Conduct, ��ɫ��Ƶ has developed training which all colleagues are required to complete annually to ensure that employees are empowered to make the right decisions. 

��ɫ��Ƶ encourages employees to report concerns they may have about ��ɫ��Ƶ’s compliance with applicable laws and/or breaches of its own ethical standards, including our Code of Conduct, without fear of retaliation.

Risk Management

In FY24 we partnered with EcoVadis and asked our top suppliers by emissions to complete the EcoVadis sustainability assessment. This assessment covers ESG performance including environmental management, carbon emissions, human rights, labour rights and health and safety. In addition, the reporting suite allows our Procurement team to see a range of supplier performance KPIs covering a huge amount of key information, including for example, whether the vendor has a Modern Slavery Statement and/or an Anti-Bribery & Corruption Policy. 

We also use this process in onboarding new significant 3rd party suppliers into our supply chain.

Due Diligence

Our standard terms and conditions include a clause that all suppliers are required to comply with our Supplier Code of Conduct under which Suppliers are expected to uphold the highest standards of human and labour rights. We have a zero-tolerance approach for any breaches against this policy and will terminate any agreement if there are any breaches or suppliers cannot demonstrate compliance with ��ɫ��Ƶ policies. 

We have invested in third party systems and tools, such as SEON, that provide strong identity verification. Processes for the assessment and implementation of these were designed and carried out successfully in 2024. Proprietary solutions have also been proposed and evaluated, increasing ��ɫ��Ƶ’ ability to separate legitimate suppliers from illegitimate actors quickly and effectively. 

We have a detailed onboarding process for all suppliers including questionnaires ensuring compliance to key areas such as but not limited to: 

• Fraud Mitigation 
• Anti bribery 
• Human Trafficking and modern slavery 
• Data Privacy 
• Environmental compliance

FY24 Progress and Effectiveness

We continue to review our policies and practices to ensure our response to modern slavery remains effective, and during FY24 we rolled out the use of Ecovadis. 

During FY25 we will continue to review modern slavery, human rights and other ESG related criteria against our supply chain with the aim of strengthening our process to identify suppliers that may be at high risk of modern slavery.

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This Statement has been approved for release by the ��ɫ��Ƶ Board of Directors and made available on our website www.rws.com.

Maria Schnell

Chief Language Officer

4 November 2024