ITS TESTING SERVICES (UK) LIMITED

Policies described

Freedom of workers to terminate employment Freedom of movement Freedom of association Prohibits any threat of violence, harassment and intimidation Prohibits the use of worker-paid recruitment fees Prohibits compulsory overtime Prohibits child labour Prohibits discrimination Prohibits confiscation of workers' original identification documents Provides access to remedy, compensation and justice for victims of modern slavery

Training described

Your whole organisation Human resources Procurement staff

Worker engagement and working conditions

Your suppliers Workers within your organisation

Social audits

Audit conducted by your staff

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app Through trade unions or other worker representative groups

Demonstrated progress

Modern Slavery is a complex risk and often hidden. We use performance indicators to monitor and report on the effectiveness of our policies and procedures in this area. These can be found in our Modern Slavery Act Statement, page 10. As part of our commitment to transparency and accountability, we will regularly review and report on our progress towards compliance with the Modern Slavery Acts and eradicating modern slavery from our supply chain.

Reported risks and mitigations

• Risk: We have a number of seasonal workers in higher-risk countries, including a few migrant workers in certain countries.
• Area: Within your own operations
• Group: Women Migrants
• Mitigation: We have undertaken a risk identification and assessment process within our risk committees and sought input from experts to understand our risks and opportunities to combat modern slavery. We are aware that such workers are at increased risk of abuses (such as excessive working hours and withholding of salaries) with reduced access to legal protections. We believe that our on-boarding, training, monitoring and reporting processes adequately mitigate the increased risk to these workers.
• Risk: We deploy inspectors to ports and terminals around the world to attend the discharge of cargo vessels.
• Group: Other vulnerable groups
• Mitigation: We believe that our training of inspectors, our close monitoring of their working time and our technology-enabled scheduling solutions mitigates this risk.
• Risk: We remain vigilant to the use of modern slavery in higher risk areas such as security, office cleaning and catering services.
• Area: Within your supply chains
• Tier: Tier 1 suppliers Tier 2 suppliers
• Group: Women Migrants Refugees
• Mitigation: We re-enforce our Code of Ethics with our business partners, including contractors, sub-contractors, and suppliers, who are required to commit to its principles before we enter into contracts with them. We performance of due diligence on suppliers. Supplier onboarding process includes communication of the expectation to comply with our policies and agreements, including our Modern Slavery Policy, Code of Ethics and Labour and Human Rights Policy.