Anti-Slavery Policy

GROUP POLICY

1.Policy Statement

Goodman Topco Limited and its subsidiaries (“NoBlue2”) is committed to acting ethically and with integrity and transparency in all business dealings and to safeguard against any form of modern slavery taking place within the business or our business partner network.

The purpose of this Anti-Slavery Policy is to provide staff with a clear set of guidelines to ensure that modern slavery or human trafficking is not taking place within our business our business network.

This policy is applicable to all employees, contract workers and temporary staff.

2. Definition

Modern slavery refers to various forms of exploitation and abuse where individuals are subjected to forced labor, human trafficking, slavery, or other practices that deprive them of their freedom. It involves coercion, deception, or force to exploit people for labor or services against their will, and it is a serious violation of human rights.

3. Policy

We operate a number of internal procedures to ensure that we are conducting business in an ethical and transparent manner. These include:

• Anti-slavery policy. This policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help.

• Recruitment procedure. We operate a robust recruitment policy, including conducting ‘eligibility to work in the UK’ checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.

• Whistleblowing. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or wider business network, without fear of reprisal.

• Corporate & Social Responsibility. This explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.

4. Suppliers

NoBlue2 has a relatively small number of active suppliers and we conduct due diligence on the larger key partners to satisfy ourselves they have robust anti-slavery policies.

For reference links to these policies are below:

http://www.oracle.com/us/corporate/human-trafficking-policy-2967692.pdf

https://query.prod.cms.rt.microsoft.com/cms/api/am/binary/RE1JskG

https://www.sage.com/investors/corporate-governance/anti-slavery-and-human-trafficking-statement/

5. Reporting

In the first instance employees should report any concerns they may have to their line manager. If it is not appropriate to make the report to the line manager, employees should instead report to another manager of equal or greater seniority, where possible.

All concerns reported will be treated in the utmost confidence. Information Classification: Internal

Following receipt of a report, an investigation meeting will be held. The purpose of this meeting is to gather as much information as possible regarding the concerns raised, including whether there is any supporting evidence or witnesses.

After this meeting, the investigating manager will commence a full investigation into the concerns raised. The investigation will aim to gather all relevant information including relevant documentary evidence or witness statements.

6. Formal action

Should formal action be required as a result of any report made under this policy, this action will be carried out in accordance with the applicable internal policy. Any potential sanctions imposed will be fair and reasonable in line with the relevant policy.