SCOTTISH WATER BUSINESS STREAM LIMITED

Policies described

Freedom of workers to terminate employment Freedom of association Prohibits any threat of violence, harassment and intimidation 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

Procurement staff

Worker engagement and working conditions

Your suppliers Trade unions or worker representative groups Workers within your organisation Workers within your supply chain

Social audits

Audit conducted by your staff Audit conducted by your supplier’s staff

Grievance mechanisms

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

Other monitoring

Annually we ask all key suppliers to submit changes to the working conditions. Where changes have been made we request further information and/or audit the suppliers site where the work takes place.

Demonstrated progress

In our statement each year we explain what we have done to demonstrate progress and we set out what our key next steps will be. We have a number of KPIs we measure and monitor accross our Supply Chain and our business which provides confidence with our performance.

Reported risks and mitigations

• Risk: Workers in our outsourced back office in India
• Area: Within your supply chains
• Tier: Tier 1 suppliers
• Group: Migrants Refugees
• Location: India
• Mitigation: We closely monitor any changes with individuals working on our account. When on site we review their HR policies and procedures, periodically we review the team associated with the work, their employment status and working conditions.
• Risk: Temporary workers on our Meter Reading Service contract in peak demand times.
• Group: Other vulnerable groups
• Location: United Kingdom
• Mitigation: We monitor the meter readers assigned to our account. Periodically we request any updates to their employment and conditions and adherence to our Anti-Slavery Policy.
• Risk: Supply of temporary workers for our contact center
• Area: Within your own operations
• Mitigation: We have an approved set of Agencies which are used when an Agency approach is required for recruitment. To become an approved agency due diligence is carried out to ensure they are reputable and have a zero tolerance to Modern Slavery. As all of our key suppliers are required to do is periodically they need to confirm compliance to our policies and provide any changes to their processes.