• Have incorporated the Policy into our Business Conduct Principles for suppliers, subcontractors and partners (“Business Conduct Principles”). The Business Conduct Principles apply to our suppliers, contractors and partners.
• Publish the Policy on the website of each applicable Group Company, for public access.
• Publish our Business Conduct Principles; these are currently available via the Esri UK website (www.esriuk.com).
• Have incorporated the Business Conduct Principles and thereby the Policy into applicable Purchasing Terms (currently applicable to Esri UK and Esri Ireland). The Purchasing Terms apply to most of our suppliers.
• Include acceptance of the Policy as a pre-condition in our supplier pre-approval process.
• Undertake any necessary due diligence on organisations within the supply chain to ensure their suitability and ability to comply with the Policy.

During the 2023 Financial Year we will ensure that the above continues to apply.

The parts of the Group Companies’ business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps taken to assess and manage that risk

Suppliers and subcontractors: there may be a risk of slavery and/or human trafficking through organisations with whom we contract for the supply of products or services, or through organisations with whom we subcontract work to or partner with.

The appointment of suppliers and subcontractors is subject to careful due diligence to ensure that there is no perceivable risk of slavery and/or human trafficking. We engage only with reputable suppliers or parties that do not engage in any form of slavery and/or human trafficking.

All such parties are expected to adhere to the Business Conduct Principles, which for Esri UK and Esri Ireland have been incorporated into the process for being appointed as such and/or the relevant contractual relationship.

We avoid contracting with suppliers or subcontractors which are located within geographical areas where slavery and/or human trafficking are a risk. In the event that we need to contract with suppliers or subcontractors outside of the United Kingdom, we assess the supplier/subcontractor and the relevant geographic area on a case by case basis, undertaking any necessary due diligence in accordance with the paragraph below.

We do not permit our suppliers to subcontract work or to supply products from any third party, save where our prior written permission is first obtained. In such situations the supplier is required to undertake adequate due diligence to ensure and to satisfy us that there is no risk of slavery and/or human trafficking in the third party’s supply chain.

Our ISO, H&S and Security Officer is responsible for any compliance matters set out in this Statement and Policy, for ensuring due diligence and for undertaking audits. Our HR Team and Legal Team are jointly responsible for ownership of this Statement and Policy, including ensuring that it is up-to-date.

Our effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate

The effectiveness of ensuring that slavery and/or human trafficking is not taking place in our business or supply chains shall be assessed by application of the following key performance indicators:

• To raise awareness of slavery and/or human trafficking by bringing the contents of the Statement and Policy to the attention of its staff, including (where applicable) by publishing it under ‘Company Policies’ on our internal portal and providing a formal notice to it on the internal portal home page. [Date required: continuous.]
• Require all staff that are to work in countries where slavery and/or human trafficking is a risk to complete specific and tailored (to the country in question) training on preventing slavery and/or human trafficking. [Date required: as and when applicable.]
• Require staff (HR Team) that induct new employees to introduce employees to the Statement and Policy. [Date required: ongoing throughout the Financial Year.]
• Provide training and guidance (Legal Team) to all employees on preventing slavery and/or human trafficking as part of staff training. Refresher training to be provided during the course of 2023. [Date required: by end of 2023.]
• Review the existing training and guidance (see bullet above) and make any required updates (including, targeted training, reporting, the indicators of modern slavery and/or human trafficking and forced labour). [Date required: by end of 2023.]
• Continue to ensure that supplier adherence to the Policy and the Business Conduct Principles is part of the supplier appointment process. All suppliers must adhere to this prior to becoming a supplier.
• Review our purchasing practices to ensure that worker conditions are not adversely impacted. [Date required: by end of 2023.]
• Review how we investigate / assess the modern slavery risks with our Associated Parties. Can we undertake activity that assists workers in our Associated Parties. Review all existing supply chains. [Date required: annually.]
• Review (i) our reporting modern slavery and/or human trafficking process, and (ii) how we respond to reports of modern slavery and/or human trafficking. [Date required: by end of 2023.]
• Update the historic copies of the Statement and Policy on our applicable websites (to include the 2022 Financial Year Statement and Policy). [Date required: by February 2023.]