The Eurasia Consortium and Associated Companies: Modern Slavery and Human Trafficking Policy

Effective Date: 01 09 2024

This document is structured to meet UK legal obligations under the Modern Slavery Act 2015 and reflects best practices in corporate responsibility.

Reviewed: Annually

1. Purpose

The Eurasia Consortium is committed to preventing modern slavery and human trafficking in all aspects of our business and supply chains. We take a zero-tolerance approach to slavery, servitude, forced labour, and human trafficking and expect the same high standards from all our contractors, suppliers, and business partners.

2. Scope

This policy applies to all individuals working for or on behalf of The Eurasia Consortium in any capacity, including employees, directors, officers, agency workers, volunteers, interns, contractors, external consultants, third-party representatives, and business partners.

3. Our Commitment

The Eurasia Consortium and its associated companies are committed to:

• Acting ethically and with integrity in all business dealings.
• Implementing effective systems and controls to ensure modern slavery is not taking place in our own business or in any of our supply chains.
• Continuously improving our practices to combat slavery and human trafficking.
•  Complying with all relevant UK legislation, including the Modern Slavery Act 2015.

4. Due Diligence and Risk Management

To identify and mitigate risk, we:

• Assess and monitor supply chain risks through supplier vetting processes.
• Require key suppliers to confirm compliance with the Modern Slavery Act.
• Include anti-slavery obligations in contracts with suppliers and contractors.
• Audit suppliers where there is a higher risk of modern slavery.
• Train relevant staff on identifying signs of slavery and human trafficking.

5. Supplier Code of Conduct

Our suppliers are expected to:

• Not use forced, bonded, or involuntary labour.
• Provide safe and hygienic working conditions.
• Pay workers fairly and in compliance with local laws.
• Ensure workers are free to leave their employment after reasonable notice.
• Not require workers to lodge deposits or identity papers.
• Suppliers that fail to meet these standards may be subject to termination of the business relationship.

6. Training and Awareness

We provide training to relevant employees to ensure a high level of understanding of the risks of modern slavery and human trafficking. This includes:

• Recognising the signs of modern slavery.
• Reporting concerns.
• Understanding our policies and procedures to combat slavery.

7. Reporting Concerns

Employees, suppliers, and other stakeholders are encouraged to report any suspicion of modern slavery in any part of our business or supply chains. Reports can be made confidentially and without fear of retaliation.

All concerns will be investigated, and appropriate action will be taken.

8. Monitoring and Review

We will:

• Review this policy annually.
• Publish a modern slavery statement each financial year on our website in line with Section 54 of the Modern Slavery Act 2015 (if applicable).
• Continually improve our procedures and training based on lessons learned.

9. Approval and Sign-off

This policy has been approved by the Board of Directors of The Eurasia Consortium and will be reviewed annually.

Signed:

Dr Stuart Kewley

Director

Date: 01092024