GATEWAY GLOBAL COMMUNICATIONS 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 Your front line staff Human resources Executive-level staff Procurement staff Your suppliers The wider community

Worker engagement and working conditions

Your suppliers Professional auditors Workers within your organisation Workers within your supply chain Businesses in your industry or sector

Social audits

Audit conducted by your staff Third party audit arranged by your organisation Audit conducted by your supplier’s staff Third party audit arranged by your supplier Announced audit

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app

Other monitoring

Corporate Policies, Supplier Codes and other corporate procedures.

Actions addressing ILO indicators

Financial remediation, including repayment of recruitment fees Change in policy Change in training

Demonstrated progress

All employees in the UK and all line managers managing UK employees are required to go through the requirements of the Company’s modern slavery policy at their annual appraisal and confirm in writing that they have read and understood the requirements of the legislation.

Reported risks and mitigations

• Risk: Vendors employing highly skilled personnel (such as engineers or other professionals).
• Area: Within your supply chains
• Tier: Tier 1 suppliers Tier 2 suppliers Tier 3 suppliers and below
• Group: Migrants
• Mitigation: The Company has continued to ensure that suppliers have reviewed and confirmed acceptance of our policy statement, in particular suppliers providing cleaning or catering services at Company facilities have confirmed that the identification documents for all personnel engaged in the provision of the services has been verified and returned to the respective individual.
• Risk: Providers of catering and cleaning services
• Tier: Tier 3 suppliers and below
• Mitigation: The Company’s Vendor Management Group has required all new vendors to sign up to the supplier code of conduct which, amongst other things, requires each respective vendor to confirm that it has taken all reasonable steps to eliminate modern slavery and human trafficking in its supply chain.
• Risk: Product manufacturers.
• Mitigation: The Company conducts proportionate due diligence on all new suppliers and, where appropriate, existing suppliers. This includes requiring acceptance of our Supplier Code of Conduct, verifying the identity of personnel where services are provided on‑site, and, for higher‑risk suppliers, reviewing labour‑related controls and policies. Our modern slavery due diligence questionnaire, currently being finalised, will form a mandatory part of pre‑engagement checks for all new vendors.