Modern Slavery

Section 54 of the Modern Slavery Act 2015 requires large employers to produce a Modern
Slavery Statement for each financial year. Whilst Delt Shared Services Ltd do not currently
have a legal obligation to publish this, we have chosen to do so. We believe the localised
nature of our activities and our customers, contractors and supplier geography, puts us at
lower risk than some in the shared service industry. Nevertheless, we remain vigilant in the
detection and prevention of modern slavery and human trafficking and have a zero-tolerance
approach to any:

• Human trafficking including all aspects of child slavery;
• Forced work through mental or physical threat;
• Being controlled or owned by an employer through mental or physical abuse or the
  threat of abuse;
• Slavery in supply chains.

We are committed to our company values of transparency and integrity and publish this
statement to outline the procedures Delt already undertakes, what we have done this year
and what we will do in the coming year. This is Delt’s first annual Modern Slavery Statement
and has been developed in accordance with the Modern Slavery Act 2015.

Delt is committed to working with suppliers to address the risk of modern slavery in our supply
chains.

Suppliers are thoroughly assessed for suitability prior to contracting. This is carried out in
two ways.

• Via our supplier onboarding process
• Suitability assessment prior to tendering potential suppliers are asked questions required under the Procurement Act 2023 enabling us to identify any previous convictions of misconduct or mistreatment of staff through their activities.

Delt expect all its suppliers to commit to the eradication of modern slavery in their direct working practices, their supply base or in their extended supply chains. Our suppliers are expected to conduct their business activities to the highest ethical standards.

Our supply chain consists of small business, SME and large corporates operating in multiple sectors regionally, nationally and internationally.

Delt will activity promote adherence to the Modern Slavery Act and will work to support and develop its smaller suppliers in this endeavour.

• Contacted all of our suppliers and baselined their progress and compliance.
• Carried a compliance assessment.
• Developed and deployed educational and training resources for our employees and communicated our requirements clearly to all our suppliers.
• Added modern slavery specific questions and governance to our supplier onboarding process and supplier due diligence checks.
• Worked both internally and within our stakeholder group to ensure that throughout all of our procurement processes we assess and report the risks around the Modern Slavery Act.

• Report to our Board annually on the results, actions and any interventions resulting from our work using the following indicators.
  100% of staff complete the compliance training regarding modern slavery.

1. Reporting the number of new suppliers in the year with confirmation they have either provided their policies and commitments to meeting the
   requirements of the MSA or successfully completed a risk assessment as part of the onboarding process.
2. Report on the number of supplier risk/suitability assessments and any outstanding actions; this will be determined by assessing scope of supply and the risk associated e.g originating country.
3. Provide a risk summary to the Board based on all ongoing risk assessments/due diligence within our supply chain(s).

• Highlight any critical issues to the Board during the year.
• Work closely with our shareholders’ procurement teams to ensure we exchange information and best practice in this area including any issues with shared suppliers.

To ensure that we’re consistent and diligent in our approach to tackling modern slavery, we train all of our staff to understand and recognise the areas and issues associated with modern slavery. As such, all of our employees through onboarding, induction and ongoing development and compliance training, undertake our mandatory e-learning training for modern slavery annually. Compliance with this requirement will be reviewed by the senior leadership team quarterly and reported to the Board annually as part of our ongoing governance.

As the business grows, naturally our supply chains will change and adapt. We are committed to constant re-evaluation of our processes and how we identify and manage areas of risk.

Delt processes provide a route for employees to raise any concerns around modern slavery that they witness in delivering to their roles and responsibilities.