Modern Slavery And Human Trafficking Policy

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors and suppliers.

Company Structure and Supply Chains

A M Phillip Group (A M Phillip Limited - Reg No: SC081280, A M Phillip Trucktech Ltd - Reg No: SC287764, Gammies Groundcare Ltd - Reg No: SC586152) are suppliers of commercial, agricultural and groundcare machinery and related goods and services. Operating out of 6 depots, the Organisation operates in a wholesale to retail structure in goods and services to the business and private sectors throughout Scotland and the British Isles.

The Organisation operates under OEM franchise supplier agreements and utilises other non-OEM suppliers for goods and services which from part of the offering either directly or indirectly.

­

Policy Definitions and Commitments

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery and Human Trafficking are crimes and a violation of fundamental human rights and an unquestionable and indefensible violation of an individual’s basic human right.

A M Phillip Group recognises that as a commercial organisation, it has a moral and social responsibility to take a zero-tolerance approach to modern slavery in all forms. We are committed to preventing modern slavery and human trafficking in our corporate activities, and to ensuring, as far as we are able, that our supply chains are free from slavery and human trafficking.

Due Diligence and Risk Assessment

We undertake due diligence when considering taking on new suppliers and are in the process of reviewing our existing suppliers. This due diligence incudes: -

• Understanding our supply chain to identify and assess particular product or geographical risks of modern slavery and human trafficking.
• Evaluating modern slavery and human trafficking risks through the completion of our supplier evaluation processes.
• Conducting supplier audits.
• Terminating our relationship with suppliers that fail to improve their performance in line with an action plan or violate our supplier code of conduct.

We are committed to ensuring that our suppliers adhere to the highest standards of ethics. Suppliers are required to declare that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labour.

As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.

If we find that other individuals or organisations working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships

Measurement and Training

We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

• We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
• The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
• We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
• We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach, we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.
• Consistent with our risk-based approach we may require:
  • Employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct
  • Suppliers engaging workers through a third party to obtain that third parties' agreement to adhere to the code

This statement has been approved by the Directors of the A M Phillip Group who will review and update it annually. This statement is made pursuant of section 54(1) of the Act and constitutes our Modern Slavery and Human Trafficking statement for the financial year ending 31 December 2022.

Signed. Rob McWilliam

Director.

Date: 18^th January 2023