Modern Slavery Statement

TFE Group Ltd
(Companies House Registration Number: SC844047)
Modern Slavery and Human Trafficking Policy
Adopted on: April 8 2025

1. Purpose and Scope

TFE Group Ltd (“the Company”) is fully committed to preventing any form of modern slavery, human trafficking, forced labour, or related human rights abuses within its operations and supply chains. This Policy applies to all Company activities, including those carried out by subsidiaries, affiliates, and any workers or suppliers acting on our behalf.

The Company recognizes its responsibility to act ethically and with integrity, consistently ensuring transparent operations. We require all employees, contractors, partners, and suppliers to uphold these principles and adhere to the highest standards of business ethics.

2. Definitions

• Modern Slavery: Encompasses slavery, servitude, forced or compulsory labour, and human trafficking, as defined under the UK Modern Slavery Act 2015 and other relevant legislation.

• Forced or Compulsory Labour: Any work or service that a person is forced to do under the threat of a penalty or harm and for which the individual has not offered themselves voluntarily.

• Human Trafficking: The act of recruiting, transporting, transferring, harboring, or receiving a person through coercion, abduction, fraud, or deception for the purpose of exploitation.

3. Statement of Commitment

1. Zero-Tolerance Approach: We maintain a zero-tolerance stance toward modern slavery and human trafficking. Any breach will be taken seriously and dealt with promptly.

2. Ethical Business Conduct: We are committed to conducting our business activities ethically, in a manner that respects human rights, and in compliance with all applicable laws and regulations.

3. Continuous Improvement: We acknowledge that combating modern slavery and human trafficking is an ongoing effort. Therefore, we regularly review and improve our processes, policies, and controls to mitigate potential risks.

4. Governance and Responsibilities

1. Board of Directors:

   • Oversee the implementation and effectiveness of this Policy.

   • Review and endorse the annual Modern Slavery Statement.

   • Ensure that all incidents reported are handled swiftly and effectively.

2. Senior Management:

   • Take responsibility for incorporating this Policy into everyday operations.

   • Provide resources for staff training and monitoring of supply chains.

   • Set objectives and performance targets to track the impact of this Policy.

3. All Employees:

   • Comply with this Policy and uphold its principles.

   • Participate in training and awareness programs as required.

   • Report any suspected or actual breaches to management as soon as possible.

5. Policies, Procedures, and Controls

1. Recruitment and Employment Practices:

   • We verify all employees’ right to work through official documentation and conduct pre-employment background checks where appropriate.

   • We implement fair recruitment practices, ensuring that no individual is forced or coerced to work for TFE Group Ltd or any supplier in our chain.

2. Supplier Due Diligence:

   • Prospective suppliers are subject to evaluation on ethical and responsible business practices, including adherence to anti-slavery standards.

   • Contracts and agreements with suppliers include commitments to prevent modern slavery and human trafficking.

   • We maintain a preferred supplier list, removing any supplier that fails to meet our ethical requirements.

3. Supplier Audits and Assessments:

   • We use audits, self-assessment questionnaires, and spot-checks to evaluate supplier compliance.

   • Where risks are identified, we work collaboratively with suppliers on corrective action plans or, if necessary, terminate relationships with non-compliant parties.

4. Risk Assessment and Management:

   • We regularly assess the risk of modern slavery in our operations and supply chain, focusing on high-risk regions, industries, or functions.

   • Appropriate remediation activities are undertaken to address any identified risks or breaches.

5. Record-Keeping:

   • We maintain records of all supplier audits, staff training, and reports of incidents or concerns related to modern slavery or human trafficking.

   • Data gathered from our monitoring activities helps us review and improve our processes on an ongoing basis.

6. Training and Awareness

1. Leadership and Senior Management:

   • Undergo in-depth training to identify, monitor, and address modern slavery and human trafficking risks.

   • Are responsible for cascading knowledge and setting the tone of ethical conduct throughout the Company.

2. All Staff Training:

   • All employees receive training to raise awareness of modern slavery and human trafficking.

   • This includes guidance on how to recognize signs of modern slavery, how to report concerns, and understanding the importance of this Policy in our day-to-day business.

3. Ongoing Education:

   • We provide refresher sessions and updated resources to address emerging risks or changes in legislation.

7. Reporting and Whistleblowing

1. Reporting Concerns:

   • Anyone with concerns or suspicions of modern slavery, human trafficking, or unethical practices is urged to report these immediately.

   • Primary contact is James Warwick, who can be reached at james@tfe.ai.

2. Whistleblowing Hotline/Procedure:

   • We maintain internal processes that guarantee confidentiality for anyone raising concerns.

   • All reports are investigated thoroughly, and whistleblowers are protected from retaliation.

3. Escalation Procedure:

   • Concerns are escalated to the board of directors or senior management in cases of severe or repeated violations.

8. Response to Reports and Remediation

1. Prompt Investigations:

   • Our board of directors ensures that all investigations are conducted quickly and effectively.

   • Investigations aim to identify the root causes and prevent future occurrences.

2. Corrective Measures:

   • If an investigation confirms violations, we act immediately to address the issue.

   • Possible actions include engaging with relevant organizations or non-profits to improve standards, removing the violating party from our supply chain, and, where applicable, involving law enforcement agencies.

3. Support to Affected Persons:

   • Where individuals are found to be affected by modern slavery, TFE Group Ltd will connect them with appropriate support services, either directly or via recognized charities and agencies.

9. Monitoring and Performance Indicators

We regularly monitor our effectiveness in combatting modern slavery using the following key performance indicators (KPIs):

1. Supplier Compliance:

   • Percentage of suppliers who sign our Code of Conduct or provide their own modern slavery statements.

2. Supply Chain Visibility:

   • Frequency and thoroughness of supplier audits, including spot checks and re-audits.

3. Training Metrics:

   • Completion rate and frequency of employee training on modern slavery and human trafficking.

   • Effectiveness of training, as assessed by internal reviews and staff feedback.

4. Incident Tracking:

   • Number of reported concerns or actual incidents of modern slavery.

   • Speed and effectiveness of investigations and remedial action.

5. Compliance Enforcement:

   • Number of suppliers or partners removed from our preferred list due to violations.

   • Corrective actions successfully implemented within our supply chain.

6. Continuous Improvement:

   • Time spent on audits, re-audits, spot checks, and due diligence reviews.

   • Ongoing updates and improvements to our Policy or related procedures.

10. Annual Modern Slavery Statement

In accordance with applicable legislation, TFE Group Ltd publishes a Modern Slavery Statement on an annual basis. This statement:

• Details the steps taken by TFE Group Ltd to prevent modern slavery and human trafficking within the Company and its supply chain over the previous year.

• Highlights our ongoing commitments, identified risks, improvements made, and future goals.

• Is approved by our board of directors prior to publication.

11. Review and Approval

This Policy was adopted on 8 April 2025, following approval by our board of directors. It is subject to an annual review to ensure that it remains current, effective, and reflective of evolving best practices and legislative requirements. Any revisions will also be approved by our board of directors prior to release.

Contact Information
For any questions or concerns related to this Policy, please contact:
James Warwick
Email: james@tfe.ai

Signed on behalf of TFE Group Ltd
Date: April 8 2025

This policy reaffirms TFE Group Ltd’s commitment to maintaining the highest standards of ethical conduct and ensuring the protection of human rights throughout its operations and supply chain.