Anti-Slavery and Anti-Trafficking Statement and Policy

In accordance with Section 54 of the Modern Slavery Act 2015, Bristol Superlight Limited (BSL) is required to prepare an anti-slavery and anti-trafficking statement for each financial year, setting out what steps it has taken to ensure that modern slavery is not taking place in its business or supply chains.

BSL operates in the Commercial Vehicle Manufacturing Industry sector and consists of, for the purposes of this statement, its wholly owned companies as listed in the Financial Statements. Its mission is to contribute to society through the pursuit of engineering at the highest international levels of excellence.

BSL has implemented an anti-slavery and anti-trafficking policy (published below) reflecting its commitment to combatting slavery and human trafficking and to acting with integrity in all its dealings, relationships, and supply chains. The policy outlines how BSL’s various procurement and HCM practices, policies and procedures ensure compliance with its policy commitment.

Throughout 2021, BSL has continued to embed and enhance the various controls and activities outlined in its policy. BSL has introduced its online training modules through WorkNest on this topic, and the continued refinement and operation of supplier due diligence and approval procedures.

BSL did not receive any reports of instances of modern slavery or human trafficking in the financial year ending 31 December 2021.

BSL will continue to raise awareness of modern slavery and human trafficking and of the need for proper due diligence and risk assessment processes to be applied by staff and suppliers, in accordance with its policy.

Modern slavery encompasses slavery, forced and compulsory labour, and human trafficking whereby individuals are deprived of their freedom and are exploited for commercial or personal gain as defined in the Modern Slavery Act 2015. BSL is committed to combatting slavery and human trafficking and to acting with integrity in all its dealings, relationships, and supply chains. It expects the same high standards from all its staff, suppliers, contractors, and those with whom it does business. This policy applies to all employees, workers, consultants, and other persons doing business with BSL including all its contractors, and suppliers.

BSL acknowledges the risk that a supply chain may involve the use of a hidden or unknown subcontractor reliant on forced labour. Although BSL considers the risk of modern slavery to be low due to the nature of its supply chains, it takes its responsibilities to combat modern slavery seriously as demonstrated by its promotion and adoption of the following policy measures:

• The prevention, detection, and reporting of modern slavery in any part of its business or supply chains is the responsibility of all those working for BSL or under its control.

• Appropriate due diligence processes must be carried out in relation to modern slavery which may include considering human rights in a sector or country, the type of sector in which a service provider operates, the countries from which services are provided, the nature of relationships with suppliers, and the complexity of supply chain(s).

• All supply chain lines need to be continually risk assessed and managed in relation to modern slavery and any high-risk suppliers audited. BSL’s standard procurement and contract procedures and documentation address anti-slavery and anti-trafficking. The trade supplier questionnaire asks questions of potential new suppliers on their compliance with the Modern Slavery Act 2015 as part of due diligence processes. Under the supplier approval process BSL’s Finance Division reviews all new suppliers, any changes to existing suppliers and re-activation requests taking this into account.

• BSL has online training modules provided by WorkNest on anti-slavery and anti-trafficking and completion is required or encouraged for a range of relevant new and existing employees, including all Finance Division staff and those in financial or purchasing roles across BSL.

• BSL highlights modern slavery issues within its ongoing communications programmes with BSL’s Departments and with current trade suppliers to maintain and increase awareness of the issue.

• BSL encourages anyone to raise any concerns about modern slavery and will support anyone who acts in good faith.

• BSL will continue to develop its commitment to combat modern slavery and human trafficking and will outline such activities within its annual anti-slavery and anti-trafficking statement.

• Any breaches of this policy may result in BSL taking disciplinary action against individual(s) and/or terminating its relationship with any organisation or supplier.