Version: 1.2

Effective date: 1st October 2023

This policy constitutes COPE’s statement pursuant to s54 of the Modern Slavery Act 2015 in addition
to the procedural safeguards to ensure that COPE complies with the Modern Slavery Act 2015 and
procedures for staff to raise concerns.

COPE’s turnover is less than the legal threshold of £36m which avoids any mandatory report writing,
however COPE believes strongly in ethical and sustainable business practices and that all possible
steps should be taken to identify and eradicate modern slavery.

'Modern slavery' is a term which encapsulates slavery, servitude, forced or compulsory labour and
human trafficking. These are criminal offences and a person is liable if they ought to know another
person is held in slavery, servitude or required to perform forced or compulsory labour.

This policy sets out how COPE ensures that modern slavery or human trafficking is not taking place
within our business or supply chain.

COPE has a zero tolerance approach to any form of modern slavery. We are committed to acting in
an ethical manner, with integrity and transparency in all business dealings. We are committed to
creating effective systems and controls in place to safeguard against any form of modern slavery
taking place within the business or our supply chain.

Our Policies
COPE operates a number of internal policies to ensure that we are conducting business in an ethical
and transparent manner. These policies constitute a safeguard against illegal and unethical practices
in relation to slavery and make direct reference to modern slavery. These include:

• Recruitment and Selection policy. COPE’s Recruitment and Selection Policy and Procedure
  takes account of relevant requirements under legislation and the principles and best practice
  associated with these legislative requirements. The policy sets out instructions for ensuring eligibility
  to work in the UK and checks all employees to safeguard against human trafficking or individuals
  being forced to work against their will.

• Whistle blowing policy. Ensures all employees know they can raise concerns about how
  colleagues are being treated, or practices within our business or supply chain, without fear of
  reprisals.

• Code of conduct. Sets out requirements related to the manner in which we behave as an
  organisation and our expectations for employees and suppliers.

• Supplier code of conduct. Sets out the standards required of our suppliers in all aspects of
  business. It works in conjunction with our Procurement policy

• Procurement policy. States our commitment to responsible and sustainable business principles
  throughout the supply chain. It sets out our principles and processes for dealing with supplies,
  including audit and due diligence where required.

Our suppliers
We operate a preferred supplier list and we conduct due diligence on all suppliers before allowing
them to become a supplier. They are required to confirm that all parts of their business operations
conform to our supplier related policies. Any supplier breaking any element, including our anti-slavery
policy will be considered in breach of contract and immediately have their supply contract terminated.

Staff Awareness
We ensure that colleagues involved in the purchase, procurement or negotiation of the purchase of
goods or services are cognisant of the provisions of the Modern Slavery Act 2015, so that they are
aware of the issues surrounding modern slavery and what steps to take if they suspect that it is
occurring. Staff who are responsible for recruiting and selecting staff are subject to the same
requirements.

Procedure for raising concerns regarding modern slavery
In the first instance, where an employee or ‘associate’ becomes aware of a matter which is
covered by the Modern Slavery Act 2015 and this policy, they should raise the matter with
their line manager. It may be appropriate for the person raising the concern to speak to a
more senior level of management where, for example, there are concerns their line manager.

• An employee or ‘associate’ has the right to ask that their concerns are treated in confidence.
  
  
• Where a concern is raised with a manager, it should be taken seriously. The manager
  should take accurate notes of the matters raised and should immediately inform a member of
  the COPE Board. The manager should then undertake a detailed investigation in order to establish the facts
  and make recommendations to ensure that concerns are appropriately addressed.

• The relevant Board member and the employee or ‘associate’ who raised the concern should
  be kept informed of the progress of the investigation into the matters raised.

• The utmost efforts will be made to secure privacy and not to reveal the identity of the person
  who has raised the concern. Where the matters revealed during an investigation require, for
  example, disciplinary or other legal action to be taken it may, however, be necessary to
  reveal the identity of the employee or ‘associate’ who made the complaint. In these
  circumstances a discussion will take place with the person involved to explain why this is
  necessary.

• In some cases, for example where external bodies such as the police become involved,
  COPE may be legally obliged to reveal the identity of the employee or ‘associate’ without
  their consent.

• A final report will be made available and its outcome shared with the COPE Board, with the
  person who raised the initial concerns and with any employee or ‘associate’ who is implicated
  in its findings in order that appropriate action may be taken.