SWIFTFORM 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 front line staff Human resources Executive-level staff Procurement staff

Worker engagement and working conditions

Your suppliers Workers within your organisation Businesses in your industry or sector

Social audits

Audit conducted by your staff

Grievance mechanisms

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

Demonstrated progress

We track KPIs such as the number of supplier audits and staff completing modern slavery training. Progress goals include expanding audits to Tier 2 and Tier 3 suppliers and increasing supplier engagement. We regularly update policies to improve due diligence and collaborate with partners to enhance supply chain transparency. Year-on-year, we monitor improvements to ensure continuous progress in addressing modern slavery risks.

Reported risks and mitigations

• Risk: Risks in Turkey/UAE supply chains, limited visibility of lower-tier suppliers, and ensuring staff awareness through mandatory modern slavery training
• Area: Within your supply chains
• Tier: Tier 2 suppliers
• Group: Migrants
• Mitigation: We reviewed supplier controls, rolled out mandatory modern slavery training to key staff, and began implementing supplier risk assessments and audit procedures. We also plan to update contracts to include termination clauses for any supplier involved in or suspected of modern slavery, and we’re strengthening collaboration between Procurement and Quality teams to monitor compliance and share best practices across the supply chain.
• Risk: Migrant or subcontracted labour in overseas supply chains where worker protections may be weak or inconsistently enforced
• Tier: Tier 1 suppliers Tier 2 suppliers Tier 3 suppliers and below
• Mitigation: We are introducing supplier risk assessments and reviewing purchasing procedures. We are also working to ensure supplier contracts include termination clauses for any involvement in modern slavery.
• Risk: UK-based vulnerable workers, including prison leavers, may face increased risk without proper oversight and support during recruitment and employment
• Area: Within your own operations
• Group: Other vulnerable groups
• Mitigation: We work closely with local communities and HM Prisons to support prison leavers. We provide thorough recruitment oversight, ongoing training, and support to vulnerable employees to ensure fair treatment and reduce risk of exploitation.