Ethics Policy, Ethical Trading Initiative (ETI) and Modern Slavery.

Go Inspire Group Limited and subsidiary companies (“Go Inspire Group”) Modern Slavery and Human Trafficking Statement

March 2020

Introduction

This Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial year April 2019 – March 2020.

The statement sets down the Go Inspire Group’s commitment to preventing slavery and human trafficking in our business activities and the steps that have been put in place with the aim of ensuring that there is no slavery or human trafficking in the group and its supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.

Organisational structure and supply chains

This statement covers the business activities of Go Inspire Group Limited and its subsidiary companies. Go Inspire Group Limited is a company incorporated in England and Wales with registered number 09903285. The registered office is at 147 Scudamore Road, Leicester, LE3 1UQ.

Go Inspire Group is a leading integrated direct marketing and multi-channel customer communications provider. We offer a complete service from customer insight, strategy and targeting development, to campaign execution and management with creative print and mail, and response capture.

The head office is in the United Kingdom with no international offices or presence.

Goods & Services

The services Go Inspire Group provides to clients are predominantly office or site based (sites being in the UK). Goods are supplied either direct to the client or, on the client’s instructions, mailed to its customers.

In terms of goods supplied to the Go Inspire Group, the majority of goods will be goods to be used in a factory and office environment.

The following is the process by which the Go Inspire Group assesses whether activities or countries are high risk in relation to modern slavery or human trafficking: Go Inspire Group is committed to continuous improvement and training in the following:

Anti-Bribery & Anti-Corruption

Health & Safety ISO 18001- IS045001
Environmental ISO 14001
Information /Security ISO 27001

All are regularly risked assessed and audited.

1. Responsibilities

Responsibility for Go Inspire Group’s anti -slavery initiatives is as follows:

1.1 – Policies: The Group HR Manager is responsible for creating and reviewing policies. The process by which policies are developed is by looking at best practice and adapting these to the needs of the Group.

1.2 – The Group HR Manager is responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking.

2. Policies

The Go Inspire Group is committed to ensuring that there is no modern slavery or human trafficking in its businesses or supply chains. This statement affirms its intention to act ethically in its business relationships.

The following policies set down Go Inspire Group’s approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.

2.1 – Whistle blowing policy

The Go Inspire Group encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.

2.2 – Anti-slavery policy

This policy outlines the actions employees should take if faced with a potential situation relating to Modern Slavery.

2.3 – Corporate Social Responsibility (“CSR”) Policy

The Go Inspire Group’s CSR policy summarises how it manages its environmental impacts and how the group works responsibly with its suppliers and local communities.

3. Due-Diligence Processes for Slavery and Human Trafficking

The Go Inspire Group undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. Its due diligence process includes building long-standing relationships with suppliers and making clear its expectations of business partners.

4. Risk Assessment

The Group Environmental, Health & Safety Manager, with the guidance of the Group HR Manager is responsible for risk assessments in respect of human rights.

5. Measuring effectiveness

Incidents relating to potential issues regarding Modern Slavery are reported to the Board via the monthly HR Board report.

6. Training

To ensure a good understanding of the risks of modern slavery and human trafficking in Go Inspire Group’s businesses and supply chains, the group conducts a program of training for all managers on an ongoing basis.

This Modern Slavery and Human Trafficking Statement has been approved and authorised by:

Name: Patrick Headley

Position: C.E.O.

Date: 25 08 20

Ethics Policy & Ethical Trading Initiative (ETI)

We seek to follow the ethical trading initiative (ETI) base code which summarises the labour standards towards which we aim to hold ourselves and our suppliers accountable.

Purpose

GI Solutions Group (“the Company”) is committed to the practice of responsible corporate behaviour

Through its business practices the Company seeks to protect and promote the human rights and basic freedoms of all its employees and agents

Further the Company is committed to protecting the rights of all of those whose work contributes to the success of the Company, including those employees and agents of suppliers to the Company

The Company is also committed to eliminating bribery and corruption. It is essential that all employees and persons associated with the Company adhere to this policy and abstain from giving or receiving bribes of any form

This policy is non-exhaustive, and all aspects of the Company’s business should be considered in the spirit of this policy

Human Rights

The Company is vehemently opposed to the use of slavery in all forms; cruel, inhuman or degrading punishments; and any attempt to control or reduce freedom of thought, conscience and religion

Employment is freely chosen

There is no forced, bonded or involuntary prison labour

Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice

The Company will ensure that all of its employees, agents and contractors are entitled to their human rights as set out in the Universal Declaration of Human Rights and the Human Rights Act 1998

The Company will not enter into any business arrangement with any person, company or organisation which fails to uphold the human rights of its workers or who breach the human rights of those affected by the organisation’s activities

Regular employment is provided

To every extent possible work performed must be on the basis of recognised employment relationship established through national law and practice. Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, subcontracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment

Freedom of association and the right to collective bargaining are respected

Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively

The employer adopts an open attitude towards the activities of trade unions and their organisational activities

Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace

Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining

Working conditions are safe and hygienic

A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment

Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers

Access to clean toilet facilities and to drinkable water, and, if appropriate, sanitary facilities for food storage shall be provided

Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers

The company observing the code shall assign responsibility for health and safety to a senior management representative

Child labour shall not be used

There shall be no new recruitment of child labour

Companies shall develop or participate in and contribute to policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child; “child” and “child labour” being defined in the appendices

Children and young persons under 18 shall not be employed at night or in hazardous conditions

These policies and procedures shall conform to the provisions of the relevant ILO Standards. (International Labour Organisation)

Workers’ Rights

The Company is committed to complying with all relevant employment legislation and regulations. The Company regards such regulations and legislation as the minimum rather than the recommended standard

No harsh or inhumane treatment is allowed

Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited

No worker should be discriminated against on the basis of age, sex, race, sexual orientation, religion or beliefs, gender reassignment, marital status or pregnancy. All workers should be treated equally. Workers with the same experience and qualifications should receive equal work

No discrimination is practised

There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation

No worker should be prevented from joining or forming a staff association or trade union, nor should any worker suffer any detriment as a result of joining, or failing to join, any such organisation

Workers should be aware of the terms and conditions of their employment or engagement from the outset. In particular workers must be made aware of the wage that they receive, when and how it is to be paid, the hours that they must work and any legal limit which exists for their protection and any overtime provisions. Workers should also be annual leave, sick leave, maternity leave, paternity leave and such other leave as is granted by legislation as a minimum

The Company does not accept any corporal punishment, harassment in any form, or bullying in any form

Living wages are paid

Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher

In any event wages should always be enough to meet basic needs and to provide some discretionary income

All workers shall be provided with written and understandable Information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid

Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded

Working hours are not excessive

Working hours comply with national laws and benchmark industry standards, whichever affords greater protection

In any event, workers shall not on a regular basis be required to work in excess of 48 hours per week and shall be provided with at least one day off for every 7 day period on average. Overtime shall be voluntary, shall not exceed 12 hours per week, shall not be demanded on a regular basis and shall always be compensated at a premium rate

Environmental Issues

The Company is committed to keeping the environmental impact of its activities to a minimum and has established an Environmental Policy in order help achieve this aim. Copies of the Environmental Policy are available Safety Health & Environment Coordinator

As an absolute minimum, the Company will ensure that it meets all applicable environmental laws in whichever jurisdiction it may be operating

Conflicts of Interest

The Company holds as fundamental to its success the trust and confidence of those with whom it deals, including clients, suppliers and employees. Conflicts of interest potentially undermine the relationship of the Company with its partners

In order to help preserve and strengthen these relationships the Company has developed an Anti-Bribery Policy, which provide rules and guidelines concerning the conduct of its officers and employees aimed at minimising the possibility of conflicts of interest and at avoiding risks associated with bribery and corruption. Copies of the Anti-Bribery Policy are available from HR Manager or the Group Chief Financial Officer

All officers, employees and representatives of the Company are expected to act honestly and within the law

Information and Confidentiality

Information received by employees, contractors or agents of the Company will not be used for any personal gain, nor will it be used for any purpose beyond that for which it was given

The Company will at all times ensure that it complies with all applicable requirements of data protection legislation (including, but not limited to, the Data Protection Act 2018) in force from time to time

Bribery and Corruption

The Company is fundamentally opposed to any acts of bribery and to the making of facilitation payments as defined by the Bribery Act 2010

Employees and any other persons associated with the Company such as agents, subsidiaries and business partners are not permitted to either offer or receive any type of bribe and /or facilitation payment

All employees are encouraged to report any suspicion of corruption or bribery within the Company in accordance with the Whistleblowing Policy available from HR Manager or Group Chief Financial Officer

Should any employee or associated person be in doubt when receiving or issuing gifts and hospitality, he/she must refer to the Gift and Hospitality Policy available from HR Manager or Group Chief Financial Officer

The Company uses its reasonable endeavours to implement the guidance principles on bribery management that are published, from time to time, by Secretary of State in accordance with Section 9 of the Bribery Act 2010

If an employee or associated person is found guilty of giving or receiving a bribe, he/she will be personally criminally liable and may be subject to disciplinary action

Anyone found guilty of bribery, will be responsible for bearing any related remedial costs such as losses, court fees or expenses

This policy has been approved & authorised by:
Name:Patrick Headley
Position: CEO
Date: 19 03 19

Ethics Policy

Purpose

GI Solutions Group is committed to the practice of responsible corporate behaviour

Through its business practices the Company seeks to protect and promote the human rights and basic freedoms of all its employees and agents

Further the Company is committed to protecting the rights of all of those whose work contributes to the success of the Company, including those employees and agents of suppliers to the Company

The Company is also committed to eliminating bribery and corruption. It is essential that all employees and persons associated with the Company adhere to this policy and abstain from giving or receiving bribes of any form

This policy is non-exhaustive, and all aspects of the Company’s business should be considered in the spirit of this policy

Human Rights

The Company is vehemently opposed to the use of slavery in all forms; cruel, inhuman or degrading punishments; and any attempt to control or reduce freedom of thought, conscience and religion

The Company will ensure that all of its employees, agents and contractors are entitled to their human rights as set out in the Universal Declaration of Human Rights and the Human Rights Act 1998

The Company will not enter into any business arrangement with any person, company or organisation which fails to uphold the human rights of its workers or who breach the human rights of those affected by the organisation’s activities

Workers’ Rights

The Company is committed to complying with all relevant employment legislation and regulations. The Company regards such regulations and legislation as the minimum rather than the recommended standard

No worker should be discriminated against on the basis of age, sex, race, sexual orientation, religion or beliefs, gender reassignment, marital status or pregnancy. All workers should be treated equally. Workers with the same experience and qualifications should receive equal pay for equal work

No worker should be prevented from joining or forming a staff association or trade union, nor should any worker suffer any detriment as a result of joining, or failing to join, any such organisation

Workers should be aware of the terms and conditions of their employment or engagement from the outset. In particular workers must be made aware of the wage that they receive, when and how it is to be paid, the hours that they must work and any legal limit which exists for their protection and any overtime provisions. Workers should also be allowed such annual leave, sick leave, maternity leave, paternity leave and such other leave as is granted by legislation as a minimum

The Company does not accept any corporal punishment, harassment in any form, or bullying in any form

Environmental Issues

The Company is committed to keeping the environmental impact of its activities to a minimum and has established an Environmental Policy in order help achieve this aim. Copies of the Environmental Policy are available from the Health, Safety & Environment Coordinator

As an absolute minimum, the Company will ensure that it meets all applicable environmental laws in whichever jurisdiction it may be operating

Conflicts of Interest

The Company holds as fundamental to its success the trust and confidence of those with whom it deals, including clients, suppliers and employees. Conflicts of interest potentially undermine the relationship of the Company with its partners

In order to help preserve and strengthen these relationships the Company has developed an Anti-Bribery Policy, which provide rules and guidelines concerning the conduct of its officers and employees aimed at minimising the possibility of conflicts of interest and at avoiding risks associated with bribery and corruption. Copies of the Anti-Bribery Policy are available from HR Manager or the Group Chief Financial Officer. All officers, employees and representatives of the Company are expected to act honestly and within the law

Information and Confidentiality

Information received by employees, contractors or agents of the Company will not be used for any personal gain, nor will it be used for any purpose beyond that for which it was given

The Company will at all times ensure that it complies with all applicable requirements of data protection legislation (including, but not limited to, the Data Protection Act 2018) in force from time to time

Shareholders and Investors

The Company, its officers, employees and representatives are committed to ensuring that no act or omission which is within their power and which would have the effect of deliberately, negligently or recklessly misleading the shareholders, creditors or other investors in the Company occurs

Suppliers and Partners

The Company expects all suppliers and partners to work towards and uphold similar ethical and moral standards

The Company will investigate the ethical record of potential new suppliers before entering into any agreement. Further, the Company reserves the right to request information from suppliers regarding the production and sources of goods supplied

The Company reserves the right to withdraw from any agreement or other arrangement with any supplier or partner who is found to have acted in contravention of the spirit or principles of this Ethical Policy

Bribery and Corruption

The Company is fundamentally opposed to any acts of bribery and to the making of facilitation payments as defined by the Bribery Act 2010

Employees and any other persons associated with the Company such as agents, subsidiaries and business partners are not permitted to either offer or receive any type of bribe and/or facilitation payment

All employees are encouraged to report any suspicion of corruption or bribery within the Company in accordance with the Whistleblowing Policy available from HR Manager

Should any employee or associated person be in doubt when receiving or issuing gifts and hospitality, he/she must refer to the Gift and Hospitality Policy available from HR Manager

The Company uses its reasonable endeavours to implement the guidance principles on bribery management that are published, from time to time, by Secretary of State in accordance with Section 9 of the Bribery Act 2010

If an employee or associated person is found guilty of giving or receiving a bribe, he/she will be personally criminally liable and may be subject to disciplinary action

Anyone found guilty of bribery, will be responsible for bearing any related remedial costs such as losses, court fees or expenses

This policy has been approved & authorised by:
Name: Patrick Headley
Position: CEO
Date: 19 03 19

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