Modern Slavery Policy

Ultimate Cell UK Ltd – Modern Slavery and Human Trafficking Compliance Policy

1. Purpose

This policy outlines Ultimate Cell UK Ltd’s commitment to preventing, identifying, and addressing all forms of
modern slavery and human trafficking within our operations and supply chains.

We are dedicated to acting ethically and with integrity in all business dealings, ensuring that slavery and
human trafficking are not present in any part of our business or among our suppliers.

2. Scope

This policy applies to:

• All Ultimate Cell UK Ltd employees, officers, directors, contractors, agents, consultants, and
  subsidiaries.
• All suppliers, service providers, and business partners engaged by the Company.

3. Policy Statement

Ultimate Cell UK Ltd operates a zero-tolerance approach to modern slavery in all its forms, including forced
labour, child labour, human trafficking, and servitude.

We are committed to upholding internationally recognised human rights standards, including:

• The UK Modern Slavery Act 2015
• The UN Guiding Principles on Business and Human Rights
• The ILO Declaration on Fundamental Principles and Rights at Work

Our expectation is that all suppliers and partners share these principles and demonstrate the same
commitment throughout their own operations and supply chains.

 

4. Governance and Responsibility

Board of Directors:

• Holds ultimate responsibility for ensuring compliance with this policy.
• Reviews annual Modern Slavery statements and related risk assessments.

Compliance and Procurement Teams:

• Implement and monitor the policy.
• Conduct supplier risk assessments and ensure contractual inclusion of anti-slavery provisions.
  Employees and Contractors:
• Must report any concerns or suspicions of modern slavery through the reporting channels provided.

5. Supplier Due Diligence

Ultimate Cell UK Ltd conducts risk-based due diligence prior to onboarding new suppliers and periodically
thereafter.

This includes:

• Assessing country, sector, and product-specific risks.
• Reviewing supplier labour practices, certifications, and ethical standards.
• Requiring suppliers to complete a compliance questionnaire and provide documentation evidencing
  their anti-slavery measures.

Where higher risk is identified, additional verification steps or on-site audits may be undertaken.

6. Contractual Controls

All supplier contracts must include Modern Slavery compliance clauses, requiring suppliers to:

• Comply with all applicable anti-slavery laws and regulations.
• Implement policies and controls that prevent modern slavery.
• Allow Ultimate Cell UK Ltd or its representatives to audit compliance.
• Report any actual or suspected breaches immediately.

Failure to comply will result in corrective action, suspension, or termination of contract.

7. Training and Awareness

• All staff involved in procurement, supply chain management, and recruitment will receive training on
  identifying and mitigating the risks of modern slavery.
• Awareness materials will be made available to all employees and suppliers to support vigilance and
  compliance.

 

8. Reporting and Whistleblowing

Ultimate Cell UK Ltd encourages employees, contractors, and suppliers to raise concerns about any suspicion
of slavery or human trafficking.
Reports can be made through the confidential whistleblowing procedure or directly to the Compliance Officer.
All reports will be handled confidentially and investigated promptly.
No individual will suffer retaliation or disadvantage for reporting concerns in good faith.

 

9. Monitoring and Auditing

• Supplier compliance will be reviewed periodically through audits, questionnaires, and performance
  evaluations.
• Non-compliance will trigger remediation plans or contractual termination if appropriate.
• Findings will inform future risk assessments and policy improvements.

 

10. Continuous Improvement

Ultimate Cell UK Ltd is committed to ongoing improvement by:

• Regularly reviewing this policy and related procedures.
• Engaging suppliers to improve transparency and ethical practices.
• Updating risk assessments to reflect changing global supply chain conditions.

 

11. Communication and Transparency

Our Modern Slavery Policy and annual Modern Slavery Statement will be:

• Published on the Ultimate Cell UK Ltd website.
• Communicated to all employees, suppliers, and stakeholders.
• Updated annually to reflect progress and developments.

 

12. Breaches and Enforcement

Any employee, contractor, or supplier found to have engaged in modern slavery practices, or to have failed to
act in accordance with this policy, will face disciplinary action and possible legal consequences, including
contract termination and notification to the authorities.

 

13. Policy Governance, Review and Approval

Policy No.: UC-HR-005
Policy Owner: Compliance & Procurement Department
Version: 2.0
Approved by: Managing Director
Effective Date: January 2025
Next Review: January 2026