Modern Slavery Policy

NEWMARK SECURITY PLC

POLICY STATEMENT AND STATEMENT IN RELATION TO THE MODERN SLAVERY ACT 2015

Introduction

This statement sets out Newmark Security PLC’s actions to understand all potential modern slavery risks related to its business and to put in place steps aimed at ensuring that there is no slavery or human trafficking in its own business or its supply chains.

The Company is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Definitions

Human Trafficking: the recruitment, transportation, transfer, harboring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation.

Forced Labor: all work or service, not voluntarily performed, that is obtained from an individual under the threat of force or penalty.

Harmful Child Labor: consists of the employment of children that is economically exploitative or is likely to be hazardous to, or interfere with, the child’s education, or to be harmful to the child’s health, or physical, mental, spiritual, moral, or social development.

Organizational structure and supply chains

This statement covers the activities of Newmark Security PLC:

The Company is principally engaged in human capital management, electronic and physical security systems and operates through two established and wholly owned divisions:

Grosvenor Technology Limited operates in the United Kingdom and the United States and serves the human capital management and access control markets globally, offering a tailored approach that provides software and hardware solutions for a broad range of end users; and
Safetell Limited, operates in the United Kingdom and designs, develops, installs and maintains a diverse range of physical security solutions in various sectors and countries; protecting businesses around the clock with its field-based technicians and engineers.

Grosvenor Technology’s supply chain is primarily from within the European Union and United Kingdom with a small number of suppliers in Asia (which are mainly sub-contractors for UK or EU registered companies).

Safetell’s supply chain is primarily in the United Kingdom with a few suppliers from the European Union.

High-risk activities

Newmark does not consider any of the Company’s activities within the United Kingdom, the European Union or the United States to be at high risk of slavery or human trafficking.
The small number of suppliers from outside these regions potentially present a higher risk of slavery or human trafficking and for this reason greater due diligence is taken when assessing and monitoring these.

Responsibility

Responsibility for the organization’s anti-slavery initiatives is as follows:

Policies: Newmark Security group is listed on the AIM Market (AIM) and all group policies are developed by the Human Recourses department with input and final approval by the Board of Directors.

Risk assessments: Newmark PLC recognizes its responsibility with respect to slavery and human trafficking and takes this into account when procuring products from countries outside the United Kingdom or European Union.
Investigations/due diligence: Responsibility for due diligence in assessing new suppliers rests with the Directors of Grosvenor Technology and Safetell respectively and a proper investigation will be conducted if instances of slavery or human trafficking are suspected.
Training: All staff are made aware of this policy and this is included in staff induction training as well as forming part of the employee handbook and additional policies which are updated and issued regularly to all Group employees.

Relevant policies

The Company operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

Whistleblowing Policy. The Company encourages all workers, customers and other business partners to report any concerns related to the direct activities or the supply chains of the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company’s whistleblowing policy is designed to make it easy for workers to make disclosures without fear of retaliation. Employees, or others, who have concerns can contact the Human Resources Department or a Director.
Employee Handbook. The Company’s Employee Handbooks make it clear to employees the actions and behavior expected of them when representing the Company. The Company strives to maintain the highest standards of employee conduct and ethical behavior when operating abroad and managing its supply chain.

Supplier/Procurement code of conduct. All suppliers are assessed through the ISO 90001:2015 quality management system and the Company is committed to ensuring that its suppliers adhere to the highest standards of morals and ethics. Suppliers are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect and act ethically and within the law in their use of labor. The Company works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions where necessary. Serious violations of the Company’s supplier code of conduct will lead to the termination of the business relationship. All suppliers will be made aware that the Newmark Group will not be associated with organizations that are involved in slavery or human trafficking and this will be communicated to them annually. Specifically, Grosvenor Technology & Safetell will send suppliers a copy of this Policy Statement and request written confirmation that the supplier does not partake in slavery or human.
Recruitment Commitment. The Company uses only specified, reputable employment agencies to source labor and always verifies the practices of any new agency it is using before accepting workers from that agency. All employees of the business are required to show proof of their right to work along with Security Vetting, up to BS7858:2002 standards, where required. By ensuring that Recruitment agencies used are members of the Recruitment and Employment Confederation (REC), in turn, the professional body sets standards to be followed in the recruitment process.

Due diligence

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence and reviews include:

Evaluating the modern slavery and human trafficking risks of each new supplier; this may be part of a more general human rights or labor rights assessment;
Reviewing on a regular basis all aspects of the supply chain and conducting audits of individual suppliers as appropriate.

Training

The Company requires management and all staff who are responsible for procurement to be aware of modern slavery as part of the induction process.

The Company’s modern slavery training covers:

the issue of this Policy Statement;
how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
how to identify the signs of slavery and human trafficking;
what initial steps should be taken if slavery or human trafficking is suspected;
how to escalate potential slavery or human trafficking issues to the relevant parties within the organization;
what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labor Abuse Authority and “Stronger Together” initiative;
what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
what steps the Company should take if suppliers or contractors do not implement anti- slavery policies in high-risk scenarios, including their removal from the Company’s supply

Awareness-raising program

As well as training relevant staff, the Company will continue to raise awareness of modern slavery issues by circulating this policy statement by email and including awareness in the new employee induction program.

The communication explains to staff:

the basic principles of the Modern Slavery Act 2015;
how employers can identify and prevent slavery and human trafficking;
what employees can do to flag up potential slavery or human trafficking issues to the relevant parties in the Company; and
what external help is available, for example through the Modern Slavery

Approval: Marie-Claire Dwek, Chief Executive Officer

Reviewed: Daniel Lagna, HR Business Partner Date: July 2023

Next Review: July 2024