Modern Slavery Statement

This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 and constitutes Smart
Solutions’ anti-slavery and human trafficking statement for the financial year 2025/26.

April 2025

A message from our CEO

At Smart Solutions (Recruitment) Limited, we are unwavering in our commitment to ethical business practices and integrity in everything we do. Preventing modern slavery is a critical part of this commitment, and we continue to strengthen our approach to identifying and mitigating risks within our operations and supply chain.

We recognise that the fight against modern slavery requires continuous improvement. That’s why we actively collaborate with organisations such as Slave Free Alliance (SFA), Hope for Justice (H4J), Stronger Together (S2G), and the Indirect Procurement Human Rights (IPHR) forum. These partnerships provide invaluable insights and resources, enabling us to refine our processes and enhance our safeguards.

We hold ourselves, and those we do business with, to the highest ethical standards. We expect our partners,
suppliers, and representatives to have robust measures in place to prevent modern slavery within their own
operations. To support this, we have further strengthened our internal due diligence and compliance frameworks.

Our latest Modern Slavery Statement reflects our deep commitment to eradicating modern slavery. We will
continue to challenge ourselves, evolve our approach, and drive meaningful change across our business and
industry.

Matt Spaul

Chief Executive Officer

Smart Solutions (Recruitment) Limited

Organisational Structure

Smart Solutions (Recruitment) Limited (SSR) is a partnership driven outsourced labour solution, providing innovative workforce solutions for industries across the UK and Europe.

In order to deliver the highest level of expertise for our clients, the SSR comprises of 2 Divisions, each with sector specialists working hard to ensure the highest level of service: –

Environmental Support Services – delivers a fully outsourced labour solution to the Waste and Recycling sector.
Managed Solutions – encompasses a labour-supply and on-site managed services provision which
covers a broad range of specialisms

Legislation

The Modern Slavery Act 2015 was designed to tackle slavery in the UK.

Modern slavery is a criminal offence and can happen in various forms. The offence covers slavery, servitude, human trafficking and forced labour, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal gain.

Our Employees

Smart recognises that its industry and the industries is supplies are often targeted by Gangmasters seeking to
exploit individuals for financial gain.

Our workforce consists of permanent and flexible employees who work alongside our clients and their respective
workforce.

Smart works particularly closely with our clients and other business partners to ensure consistency and
collaboration on prevention activity.

Review of Prior 12 months

Governance

Delivery of modern slavery prevention practices at Smart is led by Jade Oliver-Morris, HR & Shared Services
Director. Smart has also recently appointed Karla Conlan, a longstanding employee, into the post of Social
Impact Manager.
Overall responsibility sits with the Smart Solutions CEO, who receives regular progress reports, as does the
Senior Management Team and Group Board.

Over the last 12 months Smart have conducted an in-depth evaluation of its operating practices versus the legal
requirements to conduct right to work checks. We have reviewed our ability to implement biometric clock-in
systems in high risk and managed-service areas.
We have also continued to educate our employees on ways in which new immigration laws are impacting
modern slavery and appropriate steps to help us remain vigilant. Although Anti-Slavery practices are a
continuous focus, it is important for the business to recognise these occasions, to spread awareness and share
good practice. We also continued to use social media to promote business action as well as contributing to the
wider industry response to threat.

Partnering and collaboration

Achieving Smart’s commitment to ensure that modern slavery does not occur anywhere within its business
operations or its supply chain, requires internal drive and energy but also external expertise, knowledge and
collaboration. Smart chose to partner with Hope for Justice and Slave Free Alliance at the earliest opportunity in
its focus on anti-slavery practices.

Slave-Free Alliance is a business scheme, run by global charity “Hope for Justice”. Hope for Justice was founded in the UK in 2008 with the goals of preventing exploitation, rescuing victims, and restoring lives. Hope for Justice has since grown to become an international charity, working across four continents and running rescue programmes, aftercare facilities for vulnerable children and providing trauma care for victims of modern slavery.

Hope for Justice set up Slave-Free Alliance to work in collaboration with businesses to develop a proactive
strategy that businesses and their supply chains can adopt to deal with the threat of modern slavery. The core
objective of Slave-Free Alliance is to support businesses to work towards a slave-free organisation and supply
chain. Smart have worked with Slave Free Alliance and Hope for Justice on several occasions to present on our
organisation’s experiences and offer useful information and insight on how other organisations can do the same
thing.

Smart are also members of/licenced by the following groups/organisations: –

Indirect Procurement Human Rights Forum Waste & Recycling Working Group

The Indirect Procurement Human Rights (IPHR) Forum is a group of UK retailers, brands and manufacturers.
We have a common vision to protect and respect human rights in our goods and services not for resale supply
chains and facilitate collaborative responses to shared risks.

The IPHR Forum Waste & Recycling Working Group was formed to enable the IPHR Forum to increase and
prioritise activity to address human rights issues in the waste & recycling sector.

The Working Group includes IPHR Steering Group members in addition to stakeholders with interests in human
rights in the waste & recycling sector, including waste service providers, NGOs and Governmental bodies. Our
vision is that through collaboration, we will drive positive change to improve the human rights of workers in
waste & recycling supply chains.

Gangmasters and Labour Abuse Authority (GLAA)

The GLAA works in partnership to protect vulnerable and exploited workers. They are a Non-Departmental
Public Body (NDPB) governed by an independent board.

Their role is to protect vulnerable and exploited workers. Through intelligence, they investigate reports of
worker exploitation and illegal activity such as human trafficking, forced labour and illegal labour provision.

They investigate all aspects of labour exploitation in England and Wales and also collaborate with partner
organisations such as the police, the National Crime Agency and other government law enforcement
agencies to target, dismantle and disrupt serious and organised crime across the UK.

Stronger Together

Stronger Together is a multi-stakeholder business-led initiative aiming to reduce modern slavery particularly
forced labour, labour trafficking and other hidden third-party exploitation of workers. They provide guidance,
training, resources and a network for employers, labour providers, workers and their representatives to work
together to reduce exploitation.

Stronger Together focus on creating advice that is practical, pragmatic and easy for any business, of any size
to understand and use. Stronger Together launched in the UK in 2013 and have since grown to have a global
reach, running projects and programmes in countries across the world.

Association of Labour Providers

Established in 2004 at the instigation of the UK government, ALP is a specialist trade association promoting
responsible recruitment and good practice for organisations that supply the workforce to the food processing,
agricultural and wider consumer goods supply chain.

The ALP influences government and regulatory policy and provides a range of very useful information and
services to its members.

..The ALP’s mission is for “UK labour provision to be recognised as a model of global good practice”.

The Social Recruitment Advocacy Group (SRAG)

Smart joined SRAG in October 2023 in an effort to work with like-minded organisations to support those with
barriers within the labour market. Since joining the group, Smart has championed the need to victims of modern
slavery to be adequately represented through education, awareness and rehabilitation programmes. Smart’s
hard work was recognised with the Gold Chartermark award in September 2024 and efforts will continue towards Ambassador level in 2025.

Supply chains

Targeting modern slavery within Smart’s business operations is not enough. Smart is also committed to
addressing the risk of modern slavery in its supply chain. Smart has conducted a re-audit of its second-tier labour suppliers over the last 12 months under the framework if its supplier management processes, Supplier Code of Conduct and Supplier Evaluation Questionnaire. This specific and detailed focus on anti-Modern Slavery
practices is designed to assist us in supporting and working closely with our supply chain partners.

Ultimately, Smart expects its partners to work with it openly to identify and combat modern slavery. Smart will
only trade with those suppliers who fully comply with its Code of Conduct, or those who are taking verifiable
steps towards compliance.

Policies

Smart’s commitment to raising the bar to combat the risks of modern slavery and human trafficking in every
area of its business is also demonstrated in the following documents: –

• Hidden Labour Exploitation Policy
• Supplier Code of Conduct

Smart has a dedicated internal working group with a cross-section of skills and knowledge to drive the
programme forward including Operations, HR, Shared Services and the Group departments of IT and Finance.

Training and awareness

Training is delivered to all permanent Smart employees during induction and is refreshed annually via e-learning. Training includes how to spot the signs of Modern Slavery, escalation processes and emergency
procedures. Employees who work in ‘high risk’ geographical areas, determined by field experts, receive
advanced training. This can encompass insight into specific gangs, local intelligence and operations.

All temporary employees are trained during induction on how to spot the signs. An audit mechanism is also in
place to ensure consistency and compliance.

Various marketing techniques are used to spread awareness amongst our workforce including posters,
bathroom stall stickers, leaflets and contact cards. All marketing is translated into various languages and details
contact information for Hope for Justice and Smart’s 24/7 Confidential Helpline.

For Smart’s supply chain partners, the ‘Supplier Guide to Modern Slavery’ is communicated during the
evaluation process as part of requests for information. All 2nd tier agency suppliers are audited weekly on their
right to work checks and training, and support is provided where necessary

Remediation

Smart works with charity partners across the UK to support in placing victims of modern slavery back in to work.
Victims may have worked through Smart previously and been re-located and provided with safe harbour or may
have worked through other employers. Building relationships with such partners as The Jericho Foundation,
enable Smart to provide the most appropriate service and work assignment to a victim in line with their
rehabilitation programme. Where possible and where we have multi-site contracts, Smart will endeavour to
place a victim with the same client if they so wish. Smart offer training for specific skill areas as well as English
Language courses.

Reporting

Smart collates data on all suspect information including known associate information. Smart’s weekly reporting
from its personnel database to identify duplicates of bank account details, addresses and next of kin information
has been upgraded and anything suspicious is investigated accordingly. Smart also holds a database of
information collated through work with Police forces and Hope for Justice. Weekly reports identify changes or
additions to personnel records that match this data. Full internal investigations are conducted on any data hit.

Next Steps and Targets

Throughout the coming year, Smart will be focusing on its own internal change and staying consistent with
process and procedures across the group. We will also work to document more of our processes that are
inherent to key stakeholders but not collated formally.

We will continue to network with peers and external experts to share knowledge and experiences to understand
what works well elsewhere and identify where further improvements can be made.

We will harness the energy and commitment of our staff as we proceed on our journey, including our “Modern
Slavery Champions’ who in addition to undergoing advanced training in Modern Slavery, will act as the regional
focus for our initiatives as well as a key information sharing network internally and with key clients.

Employees who have had training strongly support our commitment to develop processes to prevent any
instances of modern slavery in our organisation. Once the role is bedded into the organisation, opportunities for
expanding the initiative into the other divisions are to be considered.

We will continue to develop our awareness programme to ensure that all staff are aware of the signs of modern
slavery and know what to do if they suspect that a colleague may be a victim.

Summary of Actions and Goals

This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 and constitutes
the Smart Solutions (Recruitment) Limited’s Modern Slavery Statement for the financial year 2025/2026.

The statement was approved by the Smart Solutions (Recruitment) Limited CEO on 24th March 2025.

Matt Spaul

Chief Executive Officer

Smart Solutions (Recruitment) Limited