Modern Slavery and Human Trafficking Policy

1. Purpose

Exell Training Ltd is committed to conducting its activities ethically and to preventing modern slavery, human trafficking, forced or compulsory labour and exploitation within its own operations and business relationships. This policy sets out the controls used to identify, prevent, report and respond to modern slavery risks.

2. Scope

This policy applies to all directors, employees, trainers, workers, contractors, consultants, suppliers, subcontractors and other business partners engaged by or acting on behalf of Exell Training Ltd.

3. Legal and Policy Framework

This policy is informed by the Modern Slavery Act 2015 and the Human Trafficking and Exploitation (Criminal Justice and Support for Victims) Act (Northern Ireland) 2015, together with applicable employment, immigration, equality, health and safety, whistleblowing and data protection requirements.

Exell Training Ltd will comply with any statutory modern slavery reporting obligation that becomes applicable to the company. Where publication is not legally mandatory, Exell may nevertheless publish information voluntarily to demonstrate transparency and responsible procurement.

4. Business Context and Risk Profile

Exell Training Ltd is a Northern Ireland training provider delivering healthcare, workplace and professional development training. Its principal modern slavery risks are considered to arise through recruitment, temporary or contracted labour, trainers and consultants, outsourced services, purchasing and the wider supply chain rather than through manufacturing operations. Risk controls are therefore applied proportionately to the nature, location and value of each relationship.

5. Standards and Prohibited Practices

Exell Training Ltd will not knowingly engage with any person or organisation involved in forced labour, servitude, human trafficking, debt bondage, unlawful recruitment fees, retention of identity documents, coercion or other exploitative labour practices.

Workers must receive clear terms of engagement, lawful pay and deductions, freedom to leave employment subject to lawful contractual notice, and access to appropriate routes for raising concerns without retaliation.

6. Recruitment and Workforce Due Diligence

• Verify identity and legal right to work where required.

• Use transparent recruitment and engagement arrangements and do not require workers to surrender passports or identity documents.

• Investigate indicators of coercion, unexplained third-party control, unlawful recruitment fees or other exploitation.

• Ensure staff and trainers know how to raise concerns and that concerns are treated seriously and confidentially as far as reasonably possible.

7. Supplier and Contractor Due Diligence

• Consider modern slavery risk when selecting and reviewing suppliers, contractors and subcontractors.

• Require compliance with applicable modern slavery and human trafficking law and Exell Training's Supplier Code of Conduct.

• Seek proportionate evidence of compliance where the nature, geography, workforce model or supply chain presents increased risk.

• Reserve the right to require corrective action, suspend activity or terminate a relationship where serious or unresolved non-compliance is identified, subject to contract and law.

8. Reporting, Escalation and Remediation

Any person who knows or suspects that modern slavery or exploitation may be occurring in connection with Exell Training should report the concern promptly to the General Manager or Director. Where there is an immediate risk of harm or suspected criminal activity, the matter will be escalated to the appropriate statutory authority or emergency service.

Exell Training will not attempt to conduct an internal investigation in a way that could place a potential victim at further risk or compromise a statutory investigation. Records will be restricted to those with a legitimate need to know and handled in accordance with applicable data protection requirements.

9. Training, Monitoring and Review

Relevant staff will receive proportionate awareness on modern slavery indicators, reporting routes and supplier due diligence. Management will review material concerns, supplier risks and actions at least annually and after any significant incident. The Director retains overall accountability for this policy.