Modern Slavery and Human Trafficking Policy

Baxter Freight has a zero-tolerance approach to modern slavery and human trafficking.

This policy sets out how we prevent, identify and respond to modern slavery risks in our business and supply chain.

Scope

This policy applies to all employees, suppliers and subcontractors, contractors, agency workers and service providers.

Our employment standards

We are committed to fair, lawful and transparent employment practices.

All employees have guaranteed contracted hours and we do not use zero hours contracts.

Part time and fixed term employees receive pro rata contractual entitlements.

We hold a National Minimum Wage certificate and maintain evidence of pay compliance.

Contracted service providers are paid in line with the Living Wage Foundation recommended rates.

These standards support fair working conditions within Baxter Freight and set clear expectations for contracted service providers.

Employees can provide feedback through Connect meetings and quarterly surveys.

Speaking up

Speak Up routes are available to employees, suppliers and third parties.

Concerns can be raised:

• with a manager
• with the HR Director
• with any member of the leadership team
• through our independent whistleblowing provider, Health Assured

Concerns can also be raised via the Health Assured confidential whistleblowing line on 0800 206 2552. Reports can be made anonymously.

All reports are managed by HR, with oversight from the Board of Directors. No one will suffer any detriment for raising a genuine concern.

Our supply chain

Our modern slavery risk sits primarily within our supply chain.

Operations is responsible for supplier onboarding and ongoing supplier management.

We:

• issue our ethical policies and standards to suppliers
• record supplier confirmation of compliance through our systems
• use compliance information as one of a number of factors to support supplier approval and ongoing supplier selection
• complete annual supplier surveys to assess labour standards and working conditions
• carry out additional due diligence where higher risk is identified. This may include requesting further information, completing a follow up review and agreeing corrective actions before approval or continued use

Suppliers are responsible for ensuring that any subcontractors used when delivering services for Baxter Freight meet the same requirements.

Where concerns are identified, they are escalated to HR for review, investigation and agreement of corrective action. Relationships may be suspended or terminated where issues are not addressed.

Training

HR is responsible for modern slavery awareness training.

All employees complete modern slavery awareness training as part of onboarding, with mandatory refresher training delivered annually. Training completion is recorded and monitored.

Responsibilities

Operations

• supplier onboarding and due diligence
• maintaining supplier compliance records
• annual supplier surveys and follow up actions where required
• escalation of concerns to HR

HR Director

• policy owner
• whistleblowing management
• investigations and corrective actions
• employee training

Board of Directors

• oversight and annual review of this policy and the Modern Slavery and Human Trafficking Statement

Monitoring and review

We monitor:

• the number of active suppliers with compliance confirmation recorded in our systems
• annual supplier survey completion
• escalations and actions closed
• employee training completion

Policy owner: HR Director
Approved by: Board of Directors
Review frequency: Annual review of this policy