Modern Slavery Policy

Modern slavery refers to situations where individuals are exploited and deprived of their freedom through coercion, forced labour, or human trafficking. It is a serious violation of human rights and can occur in any industry or supply chain. In simple terms, modern slavery means people being controlled and exploited for profit, often without choice or fair treatment.

How We Apply It for Your Benefit

At Aztec, we take a zero-tolerance approach to modern slavery. This means we:

• Implement strict policies to prevent exploitation in our operations and supply chain.
• Conduct due diligence and risk assessments on suppliers and partners.
• Provide training to our team to recognise and report any concerns.
• Maintain transparency and comply fully with the Modern Slavery Act and related legislation.

For you as a client, this ensures that the services you receive are delivered ethically, responsibly, and with respect for human rights. Our commitment protects your reputation and aligns with the highest standards of corporate responsibility.

Created 27th January 2025 – Last updated Version 3.0 (9th January 2026)

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.

We are committed to improving our practices to combat slavery and human trafficking.

Aztec is committed to social and environmental responsibility and has zero tolerance for slavery and human trafficking. We prohibit the use of forced, bonded (including debt bondage) or indentured labour, involuntary prison labour, slavery, or trafficking of persons in our business and in that of our supply chain. We consider each supplier’s conduct in regard to the above when awarding and/or renewing business with the supplier.

As Aztec does not meet the criteria set out in the Modern Slavery Act 2015 to complete a slavery and human trafficking statement, the details in this policy serve as confirmation for clients and suppliers who are required to ensure the integrity of their own supply chains.

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

To ensure that all parts of our business and supply chain are slavery free, we have reviewed our workplace policies and procedures to assess their effectiveness in identifying and tackling modern slavery issues.

Our workplace policies and procedures demonstrate our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

All our policies and procedures have been implemented in our ISOportal in accordance with the ISO 9001:2015 Quality Management System Standard and the ISO 27001:2022 Information Security Management System Standard.

As part of our initiative to identify and mitigate risk, we:

• Maintain a work environment meeting the requirements of ISO9001:2015
• Where possible, longstanding relationships are built with local suppliers and clients, clearly detailing expectations of business behaviour
• Internal assessment of supply chain based on supplier performance (e.g. audit and spot check results), and other indicators of supplier-specific risks. Our suppliers are vetted and maintained, and any issues are reported back during our management meetings or raised on the Feedback Board.
• As we have not sourced products or labour from outside of the UK, we feel that we are at a low risk of encountering supply chain members who are involved in slavery or human trafficking, but we assess each supplier on an individual basis.
• We verify our staff’s eligibility to work in the UK as part of our recruitment process. We check their National Insurance number, request photographic ID such as a passport or driving licence
• All staff are encouraged to report any concerns to top management
• All staff are aware of our sustainability and ethical ethos through ISOportal and at induction.
• Identify and assess potential risks as part of our ISO Risk Assessment Policy, utilising ISOrisk

We have zero tolerance for slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values, we have a Supplier Control Policy in place.

Adherence to our policies and procedures is maintained via our Internal Audit Programme.

Any impacts that arise relating to this policy are recorded on the Feedback Board.