Exor Freight Services Ltd Modern Slavery Statement

Modern Slavery and Human Trafficking Statement
This statement is made on behalf of Exor Freight Services Ltd pursuant to section 54(1) of the Modern Slavery Act 2015 (the ‘Act’) and constitutes our slavery and human trafficking statement. It outlines the actions and measures taken by Exor Freight Services Ltd to prevent modern slavery and human trafficking in our operations and supply chains.

Our Business and Structure
Exor Freight Services Ltd is a leading international shipping and forwarding agent. Established as a family-operated business, we have been handling international shipments for over 30 years. We import and export freight via air, road, and sea, serving customers in the United Kingdom, Europe, and Asia.

We are privately owned and have our head office in london, with regional offices in Italy

Our Supply Chains and Due Diligence Process
Exor Freight Services Ltd collaborates with customers and suppliers, including agencies that provide labor. Our supply chains involve receiving goods directly from manufacturers, customers, and their contractors for onward shipment or delivery.

We are committed to ensuring there is no modern slavery or human trafficking in our supply chain or any aspect of our business. We act ethically and with integrity in all our business relationships. We conduct due diligence when engaging new suppliers and regularly review our existing suppliers. We continuously implement and enforce effective systems and controls to prevent modern slavery and human trafficking throughout our operations and supply chains.

The extensive nature of our supply chains allows us to promote respect for human rights and positively impact people’s lives.

To assess and mitigate the risk of engaging with suppliers or contractors potentially involved in slavery, we will continue our due diligence and review practices, including:

• Pre-qualifying all new contractors or suppliers through a series of audits, incorporating Modern Slavery Act compliance into the onboarding process.
• Improving the practices of substandard suppliers by providing guidance.
• Enforcing sanctions against suppliers that fail to meet performance standards or violate our supplier code of conduct, including terminating business relationships.
• Mapping our supply chain to identify specific product or geographic risks related to modern slavery and human trafficking.
• Conducting risk assessments for each new supplier to evaluate potential risks.
• Regularly reviewing all aspects of our supply chain based on mapping results.
• Performing supplier audits or assessments focused on slavery and human trafficking when general risks are identified.
• Creating annual risk profiles for each supplier.
• Continuously monitoring potential risk areas, identifying low and high-risk areas, and outlining our responses.
• Educating and informing employees about signs of undue influence in our supply chain and how to report concerns.
• Protecting whistleblowers.

Based on our due diligence practices, we currently assess all our operations and suppliers as low risk.

We expect our suppliers and contractors to adopt a zero-tolerance approach to exploitation and to uphold the same commitment to the Modern Slavery Act that we do. To ensure this, we conduct regular compliance reviews of our existing suppliers and risk assessments of new suppliers.

Supplier Risk Assessments
When performing supplier risk assessments, we evaluate the following key factors:

• Vulnerable populations/geographic locations
• Specific products and services, as well as the raw materials used
• Governance structures in place
• Recruitment processes

In our procurement process, we only engage suppliers and contractors who confirm their compliance with the Act. We actively raise awareness among our suppliers, seeking their confirmation of compliance with the Modern Slavery Act 2015.

As part of our ongoing commitment, Exor Freight Services Ltd will continue to monitor both existing and new suppliers to ensure adherence to the MSA and our stringent internal controls. Compliance with the Modern Slavery Act is a condition for doing business with Exor Freight Services Ltd.

To that end, all new contracts and renewals now include a clause mandating compliance with the Act, granting Exor Freight Services Ltd the right to terminate contracts in case of any breach.

Exor Freight Services Ltd has established Supplier and Procurement Policies and a Code of Conduct to reinforce this statement.

We are dedicated to ensuring our suppliers adhere to the highest ethical standards. Suppliers must demonstrate safe working conditions, treat workers with dignity and respect, and act ethically within the law. We work with suppliers to help them meet our code’s standards and improve working conditions. Serious violations will result in termination of the business relationship.

Within Our Own Operations
Exor Freight Services Ltd takes several steps to ensure no slavery or human trafficking occurs within its operations:

• Adherence to relevant employment legislation promotes human rights and significantly reduces the risk of modern slavery. We ensure that workers are not exploited, are safe at work, and that all relevant employment, health and safety, and human rights laws are followed. Employees and contractors can report suspected cases of slavery or human trafficking through our internal Whistleblowing Policy.
• All employees have contracts of employment detailing their rights and obligations, including notice periods for termination. Employees may resign at any time.
• We verify employee identities and their ongoing right to work in the UK, and we do not withhold identity documents.
• We pay all employees at least the national minimum wage and comply with all legislation regarding working time and statutory leave, ensuring minimum amounts of holiday, time off for emergencies, sickness, and maternity/paternity leave, as well as required rest breaks.

Policies on Modern Slavery
We have a Modern Slavery Policy that underscores our commitment to ethical conduct in all business relationships and to implementing effective systems and controls to prevent slavery and human trafficking in our supply chains. This policy is reviewed annually and updated as needed in accordance with legal changes.

We also consider the following policies to enhance our ability to prevent modern slavery or human trafficking in our operations:

• Anti-Bribery
• Business Code of Conduct
• Equal Opportunities & Diversity
• Harassment & Bullying
• Public Interest Disclosure (Whistleblowing)
• Suppliers and Procurement Code of Conduct
• Employee Code of Conduct

Additionally, Exor Freight Services Ltd follows a Recruitment Policy and Process to ensure proper checks and practices are in place. We only use reputable employment agencies to source labor and verify their practices before accepting workers from them.

In the UK, compliance with the Modern Slavery Act 2015 will be included in our updated supplier contracts, and existing suppliers will be required to comply upon renewal.

Measuring Effectiveness
To date, we have not encountered any instances of modern slavery or related grievances. However, we have policies and procedures ready should any such instances arise.

We maintain a reporting mechanism that details policy breaches, supplier commitments to the Modern Slavery Act, and progress toward our commitments to eradicate modern slavery. These reports are shared with the Board of Directors, who oversee risk management and effectiveness. We also track data related to training for our employees and suppliers on modern slavery.

Performance Indicators
We have reviewed our key performance indicators (KPIs) and implemented the following:

• All staff are required to complete annual training on modern slavery.
• We have developed a system for verifying supply chains, assessing potential suppliers before they are integrated.

Training
To maintain awareness of modern slavery risks, we train relevant staff, and our Anti-Slavery Policy is accessible to all employees. We provide annual refresher training on the Modern Slavery Act.

All new employees receive information about the Modern Slavery Act 2015 during their induction and are directed to relevant policies.

Our modern slavery training covers:

• Our purchasing practices that impact supply chain conditions and should prevent purchases at unrealistically low prices, including the use of labor paid below national minimum wage or demanding products by unrealistic deadlines.
• How to assess risks of slavery and human trafficking related to various business aspects.
• Identifying signs of slavery and human trafficking.
• Initial steps to take if slavery or human trafficking is suspected.
• Escalation procedures for potential issues within our organization.
• Available external resources, such as the Modern Slavery Helpline and relevant authorities.
• Messages and guidance for suppliers and business partners to implement anti-slavery policies.
• Steps to take if suppliers or contractors fail to implement anti-slavery policies in high-risk situations, including their removal from our supply chains.

Awareness-Raising Program
In addition to staff training, we have raised awareness of modern slavery issues through team meetings and regular reminders.

These discussions cover:

• The principles of the Modern Slavery Act 2015
• How employers can identify and prevent slavery and human trafficking
• What employees can do to report potential issues
• Available external support, such as the Modern Slavery Helpline.

Endorsement
We fully endorse the legislation as a vital step in combating slavery and human trafficking and will not engage with any business involved in these practices, whether directly or indirectly.

We do not tolerate any behavior that contributes to human trafficking, child labor, forced or compulsory labor, or any other human rights abuses. The Board of Directors has approved this statement and appointed a Director responsible for its implementation. The Board is committed to ensuring that modern slavery and human trafficking are absent from our business operations and supply chains.