Anti-Slavery Policy

Supply Chain Standards
In our standard production procurement process, we issue purchase orders that incorporate our Terms and Conditions (T&Cs). which expand on our expectations and suppliers’ obligations on specific topics. For example, our Social Responsibility and Anti-Corruption Web-Guide outlines our prohibition of child labour, forced labour (including human trafficking), physical disciplinary abuse and any infraction of the law. Our Environmental Web-Guide sets out environmental requirements, including the elimination of materials of concern and increasing the use of sustainable materials whenever technically and economically feasible.

Internally, we have adopted our Code of Human Rights, Basic Working Conditions and Corporate Responsibility Policy, to address workplace issues such as working hours, child labour, forced labour, non-discrimination, freedom of association, health and safety and the environment. This policy applies to our own operations, and we encourage businesses throughout our supply chain to adopt and enforce similar policies in their own operations. Furthermore, we seek to identify and do business with companies that have aligned standards consistent with our CSR Policy, including working to cascade these expectations throughout their own supply chain.

Slavery and Human Trafficking
Slavery and forced labour can take many forms, including human trafficking or child labour. Paton Brown (Sales Promotions) Limited: Basic Working Conditions and Corporate Social Responsibility, clearly states that we will not tolerate forced labour (including human trafficking) or child labour in our operations and we conduct internal audits of our manufacturing locations to ensure compliance. Our processes include actions to safeguard against human rights abuses (including forced labour and human trafficking) in our supply chain, including:

• Our Global Terms and Conditions forbid the use of forced labour, child labour and physically abusive disciplinary practices. Our definition of forced labour is inclusive of human trafficking as outlined in our Policy Letter 24: Code of Human Rights, Basic Working Conditions and Corporate Responsibility.. We reserve the right to terminate our relationship with a supplier if issues of noncompliance with our policies are discovered and/or noncompliance is not addressed in a timely manner.
• We conduct training and build capability. We regularly conduct internal training on our Code of Human Rights, Basic Working Conditions and Corporate Responsibility with our Global Purchasing staff, including management and supplier quality teams. Additional training is conducted regarding our Supply Chain Sustainability Program, including coverage of the Code and our Global Working Conditions Program as required.

The board of directors of the Company delegated approval of this statement on its behalf to the Chairman and Managing Director of the Company, at its board meeting on 1st December 2017.

Kevin Griffin
Managing Director