Anti-Slavery and Human Trafficking Policy

1. Policy Statement

1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour, and human trafficking. All of these involve the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

1.2 No Worries Red Umbrella Ltd (“NWRU”, “we”, “us” or “our”) has a zero-tolerance approach to modern slavery in all its forms. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing effective systems and controls to ensure that modern slavery is not taking place anywhere in our business or in our supply chains.

1.3 We are committed to transparency in our approach to tackling modern slavery. Although our annual turnover is below the £36 million threshold that triggers a mandatory disclosure obligation under Section 54 of the Modern Slavery Act 2015, we have chosen to publish this policy voluntarily because we believe it is the right thing to do and because it reflects the expectations of our accreditation bodies, agency partners and the workers we employ.

1.4 We expect the same high standards from all our contractors, suppliers, recruitment agency partners and other business associates. As part of our engagement processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children.

1.5 This policy applies to all persons working for us or on our behalf in any capacity, including directors, employees at all levels, umbrella workers on our payroll, agency partners, suppliers, consultants and other business partners.

1.6 This policy does not form part of any employee’s contract of employment and may be amended at any time.

2. Our Business and Supply Chain

2.1 NWRU is an FCSA-accredited umbrella company providing payroll and employment services to contractors and freelancers in the United Kingdom. We employ individuals on our payroll who carry out temporary work assignments sourced through recruitment agencies for a range of end clients across multiple sectors.

2.2 Our supply chain principally comprises:

• Recruitment agencies who introduce workers to us and source assignments with end clients
• End clients at whose premises or on whose projects our umbrella employees work
• Professional service providers including accountants, legal advisers, IT service providers and banking/payment providers
• Identity verification providers such as Yoti

2.3 We recognise that, as an employer of temporary workers sourced through third-party agencies and placed with end clients, our business operates within a supply chain that carries inherent risks of labour exploitation. We take these risks seriously and have put in place the measures described in this policy to identify, prevent and address them.

3. Our Risk Assessment

3.1 We assess the risk of modern slavery in our business and supply chain on an ongoing basis. We consider the following factors:

• Worker vulnerability: Our workers come from a range of backgrounds and nationalities. Some may be more vulnerable to exploitation, particularly those who have recently arrived in the UK, those with limited English language skills, or those with insecure immigration status.
• Agency practices: We rely on recruitment agencies to source assignments. While we work with reputable agencies, we recognise that the recruitment sector has been identified as a risk area for labour exploitation.
• Sector exposure: Our workers are placed across a range of sectors. Certain industries carry higher modern slavery risks than others.

3.2 We have assessed the overall risk to our business as low, given the nature of our workforce (predominantly skilled contractors and freelancers in professional and technical roles) and the controls we have in place. However, we remain vigilant and continue to monitor and reassess our risk profile.

4. Due Diligence and Prevention Measures

We have implemented the following measures to identify and prevent modern slavery in our business and supply chain:

4.1 Worker Onboarding and Right to Work

• We verify the identity of every worker before they join our payroll, using Yoti identity verification or equivalent document checks.
• We carry out right-to-work checks on every worker in accordance with Home Office guidance, including verifying original documents, checking Home Office online share codes where applicable, and retaining copies on file.
• We ensure that every worker has a genuine contract of employment, understands their terms and is paid at least the National Minimum Wage (or National Living Wage, as applicable) through compliant PAYE payroll.
• We issue Key Information Documents (KIDs) to every worker before their first assignment, providing full transparency on pay, deductions and fees.

4.2 Payroll Practices

• All workers are paid through PAYE with full Real Time Information (RTI) reporting to HMRC.
• We never make deductions from pay that are not authorised by law or by the worker’s written consent.
• We do not charge workers for the provision of our payroll services (our margin is funded by the agency, not the worker).
• We do not retain workers’ identity documents or passports.

4.3 Agency Due Diligence

• We carry out checks on recruitment agencies before entering into business relationships with them.
• Our agency agreements include provisions requiring agencies to comply with all applicable employment and anti-slavery legislation.
• Where we become aware of concerns about an agency’s practices, we will investigate and, where necessary, terminate the relationship.

4.4 Ongoing Monitoring

• We monitor for indicators of modern slavery throughout the employment relationship (see Section 5 below).
• Our compliance dashboard provides oversight of worker assignments, payment patterns and any anomalies that may indicate exploitation.
• We maintain open lines of communication with our workers and encourage them to raise concerns directly with us.

5. Indicators of Modern Slavery

We train our staff to recognise potential indicators of modern slavery. While no single indicator proves that modern slavery is taking place, the following warning signs should prompt further investigation:

• A worker appears to be under the control of another person or is accompanied to and from work by the same individual
• A worker is unable to speak freely, appears fearful or withdrawn, or avoids eye contact
• A worker appears to have had their identity documents confiscated
• A worker is living in poor or overcrowded conditions provided by a third party connected to their work
• A worker’s pay is being collected by someone else, or the worker appears to have little or no access to their own earnings
• A worker shows signs of physical abuse, malnourishment or untreated medical conditions
• A worker is reluctant to provide personal details or gives inconsistent information about their circumstances
• A worker appears to be working excessively long hours over extended periods without adequate rest

If you observe any of these indicators, please report your concerns immediately using the process set out in Section 7 below.

6. Responsibility for This Policy

6.1 The directors of NWRU have overall responsibility for ensuring this policy complies with our legal and ethical obligations and that all those under our control comply with it.

6.2 Our UK Operations Manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with queries, and auditing internal control systems and procedures to ensure they are effective in identifying and preventing modern slavery.

6.3 Managers at all levels are responsible for ensuring those reporting to them understand and comply with this policy.

6.4 We welcome comments and suggestions on how this policy might be improved. These should be directed to our Operations Manager at hello@noworriesumbrella.co.uk.

7. Reporting Concerns

7.1 The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or on our behalf. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

7.2 If you believe or suspect that modern slavery is taking place in any part of our business or supply chain, or if you have concerns about the treatment of any worker, you must report this as soon as possible to:

• Our Operations Manager at hello@noworriesumbrella.co.uk or by telephoning 0203 137 4256
• The Modern Slavery Helpline on 08000 121 700 (run by Unseen, available 24/7)
• The police by calling 101 (or 999 in an emergency)
• The Gangmasters and Labour Abuse Authority (GLAA) at intelligence@gla.gov.uk or 0800 432 0804, if the concern involves labour exploitation in a regulated sector

7.3 You can also report concerns anonymously through the Modern Slavery Helpline or through Crimestoppers on 0800 555 111.

7.4 We encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery is or may be taking place. This commitment is consistent with our obligations under the Public Interest Disclosure Act 1998 (commonly known as “whistleblowing” legislation).

7.5 Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe you have suffered any such treatment, you should inform our Operations Manager immediately. If the matter is not remedied and you are an employee, you should raise it formally using our Grievance Procedure.

8. Training and Awareness

8.1 Training on this policy forms part of our induction process for all new employees and workers. We provide guidance on recognising the indicators of modern slavery and on how to report concerns.

8.2 Refresher training is provided periodically, and our staff are kept informed of any relevant changes to legislation or guidance.

8.3 Our zero-tolerance approach to modern slavery is communicated to all recruitment agency partners and suppliers at the outset of our business relationship with them and reinforced as appropriate.

9. Breaches of This Policy

9.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

9.2 We may terminate our relationship with any agency, supplier or other business partner if they breach this policy or if we reasonably believe that modern slavery is taking place in their business or supply chain and they fail to take adequate remedial action.

10. Review

10.1 This policy is reviewed annually by the directors to ensure it remains effective, up to date and aligned with current legislation and best practice guidance.

10.2 This policy was last reviewed and approved by the directors of No Worries Red Umbrella Ltd in February 2026.