MODERN SLAVERY ACT

This statement aims to ensure that XPGroup Holdings operates in a way that is mindful of the obligations of section 54 of the Modern Slavery Act 2015 that are applicable to organisations with a turnover of £36,000,000 or more, notwithstanding that XPGroup Holdings is not of sufficient size to be bound by the terms of that Act.

XPGroup Holdings is committed to ensuring that all of its business operations are free from involvement with slavery or human trafficking.

Slavery is a crime and a violation of human rights. It may take different forms, including slavery, servitude, forced and compulsory labour and human trafficking, all of which deprive an individual of his or her liberty in order to exploit them for personal or commercial gain. XPGroup Holdings has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place within our own business or our supply chains.

We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, in the coming year we will ask our suppliers to ensure that they are not complicit in the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude and we expect that our suppliers will hold their own suppliers to the same high standards. We are committed to the highest ethical standards of business and ensuring there is no slavery or human trafficking in any part of our business or supply chain.

XPGroup Holdings is committed to: 

• Ensuring that slavery and human trafficking is considered and addressed in our approach to corporate social responsibility
• Ensuring that any concerns about slavery or human trafficking can be raised through our whistleblowing procedure
• Carrying out regular audits to ensure that all our employees are paid at least the National Minimum Wage and have the right to work in the UK
• Ensuring that our commercial agreements reflect our expectation that our suppliers operate in accordance with the Modern Slavery Act 2015, encouraging their suppliers and sub-contractors also to operate in accordance with the Act
• Identifying and addressing any areas of high risk in our supply chain
• Providing our employees with sufficient information and training as appropriate to ensure an understanding of this policy and the importance of XPGroup Holdings Ltd’s compliance with it.

The Board of Directors has overall responsibility for ensuring compliance with our legal and ethical obligations ensuring that our employees comply with it and are aware of our Anti-Slavery and Human Trafficking Policy.

Management at all levels of XPGroup Holdings are responsible for ensuring that those reporting to them understand and comply with this policy. Any employee who breaches this policy will face disciplinary action.

We reserve the right to terminate our relationship with other businesses, contractors or organisations working on our behalf if they breach this policy.

The Board of Directors will review the policy on a regular basis to ensure that it remains fit for purpose in supporting our aim of ensuring that our business is free from involvement with slavery or human trafficking.