Modern Slavery & Human Trafficking Statement

Modern slavery is a global issue consisting of the exploitation of human beings for commercial gain.

The International Labour Organisation has estimated that there are approximately 24.9 million victims of forced labour globally, while the Global Slavery Index estimates there to be 40.3 million victims of modern slavery.

Modern slavery is a criminal commercial enterprise, and businesses have a duty to work to avoid complicity by ensuring that supply chains are free of exploited labour, and that working conditions are fair and safe, with workers being of suitable age. Further information about modern slavery.

Nash Squared is committed to combatting slavery and human trafficking and, as such, we consider Modern Slavery to be a critical issue to Nash Squared. We have a zero-tolerance approach to all forms of modern slavery and human trafficking.

Who are Nash Squared?

Nash Squared are a global consultancy combining world class talent and technology services.

We are a services business, providing recruitment, contracting and IT solutions to a wide range of clients in various sectors, operating through a number of brands across 41 locations throughout the UK, Europe, United States, and the Asia-Pacific region.

Our brands include:

• Harvey Nash
• Crimson
• Spinks
• Talent-IT
• Nash Tech

Our service offering means that we consider that the most likely form of modern slavery applicable to our working practices is labour exploitation.

Considering the type of business activity we undertake, we consider that the primary modern slavery risk in our core service delivery is low, however there is never room for complacency, and there can always be a risk of modern slavery hidden within supply chains.

We take this responsibility very seriously, and through our Supplier Code of Conduct, ask our suppliers to do the same.

Our assessment of modern slavery risk indicates three layers of risk as follows:

Primary Risk - Internal

• Nash Squared (HNG) complicity - High
• RAG - Green
• The risk of exploitation within our core service delivery is considered to be low.

Example:

Employed or contracted staff performing specific services in Nash Squared offices, building contractors, cleaners, food preparation staff, delivery staff subject to labour exploitation, or working in poor conditions with poor remuneration

Mitigation:

Management ensure a high standard of working conditions and fair pay to all employed staff, paying particular attention to lower skilled/lower paid workers

Secondary Risk - Suppliers and Third Party Vendors

• HNG complicity - Moderate
• RAG - Amber
• The risk of exploitation of workers by suppliers is considered to be moderate.

Example:

Externally contracted staff performing specific services in supplier offices, building contractors, cleaners, food preparation staff, delivery staff subject to exploitation, or working in poor conditions with poor remuneration

Mitigation:

Local management consider the companies they engage for services including appropriate due diligence when required.

Tertiary Risk - Clients & Client Suppliers

• HNG complicity - Low
• RAG - Green / Amber
• The risk of exploitation of workers by Nash Squared Clients is considered low - moderate

Example:

Clients use staff performing specific services in client offices, building contractors, cleaners, food preparation staff, delivery staff subject to exploitation, or working in poor conditions with poor remuneration

Mitigation:

Good relationships with client contacts to identify exploitation and educate where appropriate

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Every individual working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners have a responsibility to help us reduce the risk of modern slavery taking place where at all possible.

As a UK headquartered business, we adhere to the requirements of the Modern Slavery Act 2015 and apply principles therefrom throughout our business entities.

How are we reducing risk?

Our approach to combating modern slavery is principally to reduce the risk via the following approaches:

Recruitment Practices and Fair Pay‍

We are committed to following the appropriate HR processes which include:

• HR onboarding processes which include Right to Work checks
• Applying fair pay practices which include a remuneration committee which manages pay review processes.
• In the UK we are a Real Living Wage employer - The real Living Wage is the only UK wage rate that is voluntarily paid by over 7,000 UK businesses who believe their staff deserve a wage which meets everyday needs. It is a higher rate of pay than the National Minimum wage or the living wage.
• Focusing on reducing Gender and Ethnicity pay gaps which will be published in October 2020

Education, awareness and partner collaboration

To support the development and awareness of our teams we have partnered with A21 an Anti-Human Trafficking and modern slavery awareness. We deliver training and also offer webinars and round tables via A21 not only for our colleagues but also for those in our supply chain.

Internal Controls

We use internal controls to offset and monitor the risks that modern slavery may be occurring, or likely to occur in our business practices or throughout our supply chain. We adhere to accepted principles of corporate governance, an element of which includes the necessity of incorporating effective risk management and internal controls.

As with all risk management, businesses have to understand how external risk may materialise and affect internal practices, and impact negatively upon the achievement of business objectives. Controls are internal to the business, but also outward looking.

We have regular reporting from all our business entities to report on all business risk, including actual or anticipated modern slavery risk.

Embedding communication and feedback channels

Through our D,E&I practices and HR processes we are focused on creating a safe space for all our employees. Our goal is to ensure people comfortably share any experiences or concerns they have including highlighting where they might spot instances of modern slavery or human trafficking.

Next Steps

We are focused on monitoring the risk and reviewing the impact of Covid-19. In addition to this we are:

• Reviewing our development offer for 2022/23 and will be ensuring our procurement owners, HR, finance, and compliance teams complete updated training to support awareness.
• Working with A21 to further raise awareness across the organisation on Human Trafficking and Modern Slavery via webinars and round tables.

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Name: Bev White

Title: Group CEO, Nash Squared

Last updated – 31st August 2022

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