Anti-Slavery & Human Trafficking Policy

Purpose

FWB Executive Search Limited (“FWB”) is committed to conducting business ethically, responsibly and with integrity.

We have a zero-tolerance approach to modern slavery and human trafficking and are committed to ensuring that modern slavery does not take place within our business or supply chains.

This policy sets out FWB’s approach to identifying, preventing and addressing the risks of modern slavery and human trafficking in accordance with the Modern Slavery Act 2015.

Scope

This policy applies to all employees, workers, contractors, consultants, suppliers and other individuals or organisations working for or on behalf of FWB.

We expect those we work with to share our commitment to preventing modern slavery and to operate ethically and in accordance with applicable legislation..

Our Commitment

FWB will not knowingly engage with or support any organisation involved in slavery, servitude, forced or compulsory labour, human trafficking or other forms of labour exploitation.

We are committed to:

• acting ethically and with integrity in all our business relationships;
• maintaining appropriate systems and controls to identify and manage modern slavery risks;
• operating fair and responsible recruitment and employment practices;
• carrying out proportionate due diligence on suppliers and business partners;
• encouraging employees and others to raise concerns at the earliest opportunity; and
• taking appropriate action where concerns or risks are identified.

What is Modern Slavery?

Modern slavery is a serious crime and violation of fundamental human rights. It can take a number of forms, including:

Slavery and servitude – where an individual is treated as being owned or controlled by another person.

Forced or compulsory labour – where an individual is required to work or provide a service against their will, including through threats, coercion or intimidation.

Human trafficking – the recruitment, transportation, transfer, harbouring or receipt of individuals for the purpose of exploitation.

Labour exploitation – circumstances in which an individual is exploited through their employment or working arrangements, which may include excessive working hours, withholding wages or documents, threats, restriction of movement or other forms of coercion.

Modern slavery can occur in the UK as well as internationally.

Responsibilities

The Board of Directors has overall responsibility for ensuring that FWB maintains an appropriate approach to preventing modern slavery and human trafficking.

Managers are responsible for understanding this policy, promoting appropriate standards within their teams and escalating any concerns.

Employees are expected to comply with this policy and to raise any concerns or suspicions of modern slavery within FWB’s operations or supply chain.

Everyone working for or on behalf of FWB has a responsibility to remain alert to potential indicators of exploitation and to raise concerns rather than attempting to investigate them personally.

Recruitment and Employment Practices

FWB is committed to fair and ethical recruitment and employment practices.

As part of this commitment, FWB will:

• undertake appropriate right-to-work and identity checks;
• provide employees with clear written terms and conditions of employment;
• comply with applicable employment and minimum wage legislation;
• not knowingly use recruitment practices that place workers at risk of exploitation;
• not require workers to pay recruitment fees to secure employment with FWB; and
• seek to ensure that individuals are free to leave their employment in accordance with their contractual and statutory rights.

Supplier Due Diligence

FWB takes a proportionate and risk-based approach to supplier due diligence.

When engaging new suppliers or reviewing existing relationships, we may consider:

• the nature of the goods or services being supplied;
• the supplier’s employment and labour practices;
• the use of temporary, agency or subcontracted labour;
• geographical or sector-specific risks;
• the supplier’s own policies and procedures relating to modern slavery; and
• any other factors that could indicate an increased risk of exploitation.

Where appropriate, FWB may require suppliers and business partners to confirm that they comply with applicable modern slavery legislation and maintain appropriate controls within their own operations and supply chains.

Where a higher level of risk is identified, additional information, assurances or due diligence may be requested.

Risk Assessment and Management

FWB recognises that the risk of modern slavery may vary depending on the nature of the supplier, service, sector, geographical location and workforce involved.

Potential areas of increased risk may include services involving outsourced, temporary, agency, subcontracted or lower-paid labour.

FWB will take a proportionate approach to assessing these risks and will consider whether additional due diligence or controls are required.

Our approach will be reviewed periodically to ensure it remains appropriate to the nature and scale of our business and supply chain.

Identifying and Responding to Concerns

Potential indicators of modern slavery may include an individual:

• appearing frightened, withdrawn or under the control of another person;
• being unable to freely leave their employment;
• having wages withheld or controlled by another person;
• having identity or travel documents withheld;
• working excessive hours in inappropriate conditions;
• being subjected to threats, intimidation or coercion; or
• showing other signs that their employment or movement is being controlled.

The presence of one indicator does not necessarily mean that modern slavery is occurring. However, concerns should always be reported so they can be considered appropriately.

Employees should not attempt to confront suspected perpetrators or investigate concerns themselves where doing so could place themselves or another individual at risk.

Reporting Concerns

FWB encourages employees, contractors, suppliers and business partners to raise any concern or suspicion of modern slavery or human trafficking at the earliest opportunity.

Concerns should be reported to:

Jamie Brown
Email: Jamie@fwbltd.com

Reports will be treated seriously and, where possible and appropriate, confidentially.

FWB will not tolerate victimisation or detrimental treatment of anyone who raises a genuine concern in good faith.

Where appropriate, FWB will seek specialist advice and may report concerns to the relevant authorities.

Where there is an immediate risk of harm or danger, the emergency services should be contacted.

Responding to Modern Slavery Risks

Where a potential modern slavery issue is identified, FWB will consider the circumstances carefully and take proportionate action.

Depending on the nature and seriousness of the concern, this may include:

• undertaking further due diligence;
• seeking specialist legal or professional advice;
• engaging with the relevant supplier or business partner;
• requiring corrective or remedial action;
• taking steps to safeguard potential victims;
• reporting concerns to appropriate authorities; and/or
• suspending or terminating a business relationship where appropriate.

FWB recognises that immediately terminating a supplier relationship may not always be the most appropriate response where doing so could increase the risk to affected individuals. Decisions will therefore take account of the circumstances and the welfare of potential victims.

Training and Awareness

FWB will provide appropriate information and training to employees to support awareness of modern slavery and human trafficking.

Training and awareness may include:

• understanding modern slavery and human trafficking;
• recognising potential signs of exploitation;
• understanding FWB’s responsibilities and controls; and
• knowing how and where to report concerns.

Additional guidance or training may be provided to employees with particular responsibility for procurement, supplier management, recruitment or other higher-risk activities.

Your existing policy already commits FWB to employee training on the Modern Slavery Act, recognising signs and reporting concerns. Anti-Slavery & Human Trafficking.

Monitoring and Review

FWB will periodically review the effectiveness of its approach to preventing modern slavery.

This may include consideration of:

• any concerns or incidents reported;
• supplier due diligence undertaken;
• identified areas of increased risk;
• actions taken in response to concerns;
• employee training and awareness; and
• any relevant changes to legislation or Government guidance.

This policy will be reviewed at least annually, or sooner where there is a significant change to legislation, guidance, FWB’s operations or its supply chain.

Breaches of this Policy

Any employee who breaches this policy may be subject to disciplinary action, which could result in dismissal for misconduct or gross misconduct, in accordance with FWB’s disciplinary procedures.

FWB may also review, suspend or terminate its relationship with contractors, suppliers or other organisations working on its behalf where they fail to meet the standards expected under this policy.

This retains the approach already contained within your existing policy. Anti-Slavery & Human Trafficking.

15. Modern Slavery Statement

Where FWB is legally required to publish an annual slavery and human trafficking statement under section 54 of the Modern Slavery Act 2015, it will do so in accordance with the applicable statutory requirements.

Where FWB is not subject to the statutory reporting requirement, it may nevertheless provide information about its approach to preventing modern slavery to clients, prospective clients, tendering authorities and other stakeholders where appropriate.

Policy Owner: Head of Business Support / Managing Director
Approved by: Board of Directors
Effective Date: 7 October 2026
Review Date: 7 October 2026