Effective Date: 22.09.2026

Reviewed: 22.09.2026

Approved by: Senior Management Team

1. Policy Statement
Day Impex Ltd (Day-Impex) is committed to preventing modern slavery, human trafficking, forced or compulsory labour, servitude and exploitation in its own operations and supply chains. Day-Impex applies a zero-tolerance approach to modern slavery and seeks to manage risk through proportionate, risk-based procurement, due diligence, contractual controls, worker protections, training, monitoring and continuous improvement.
This document serves as Day-Impex's modern slavery policy and annual transparency statement for procurement and supply-chain purposes. It applies to the goods and services Day-Impex purchases, manufactures, distributes or resells, including activity carried out by suppliers, contractors, service providers, labour providers and relevant business partners.

2. Scope and Responsibilities
This policy applies to all employees, directors, contractors and relevant temporary workers of Day-Impex, and sets minimum expectations for suppliers and business partners. Requirements are applied proportionately according to the nature and level of modern slavery risk.

• The Board of Directors is responsible for approving this statement and overseeing the effectiveness of Day-Impex's approach.
• Senior Management is responsible for implementation, escalation of material risks, corrective action and annual review.
• Procurement, sales, operations and other relevant staff are responsible for applying due diligence and reporting concerns.
• Suppliers are responsible for meeting the standards in this policy and for cascading equivalent expectations through their own relevant supply chains where proportionate.

3. Board Approval, Publication and Communication
The latest statement will be submitted to the Board of Directors (or equivalent management body) for formal approval. The approved statement will record the approval date and will be signed by a director or equivalent authorised officer.
Following approval, Day-Impex will publish the statement on its website and maintain a clearly identifiable and prominent link from the homepage. Where a website is unavailable, a copy will be provided to any person making a written request within 30 days. Previous statements will be retained where practical to demonstrate progress over time.
The policy is made available and communicated to Day-Impex workers through induction, internal controlled-document access and relevant training. It is also communicated to suppliers through onboarding, due diligence, contractual documentation and supplier review processes. Higher-risk suppliers must acknowledge the applicable requirements and provide evidence of implementation when requested.

4. Core Labour and Human Rights Standards
Day-Impex requires its own operations and expects its suppliers and contractors to uphold the following minimum standards:

• Compliance with applicable local, national and international labour laws and regulations.
• Workers must be free to terminate employment in accordance with lawful notice arrangements and must not be prevented from leaving employment through coercion, debt, document retention or threats.
• Freedom of movement must be respected and workers must not be unlawfully confined, restricted or isolated.
• Freedom of association, collective bargaining and lawful worker representation must be respected.
• Violence, threats, harassment, intimidation, coercion and abuse are prohibited.
• Worker-paid recruitment fees are prohibited. Recruitment costs must not create or contribute to debt bondage.
• Compulsory or forced overtime is prohibited. Overtime must be lawful, voluntary where required by law, and managed so that working hours are safe and reasonable.
• Child labour is prohibited in accordance with applicable law and relevant international labour standards.
• Discrimination in recruitment, employment, pay, treatment or access to opportunity is prohibited.
• Original identity documents, passports or work permits must not be confiscated or retained as a condition of employment.
• Workers must have access to safe grievance and reporting routes without retaliation.
• Where modern slavery or exploitation is identified, Day-Impex will prioritise victim safety and access to appropriate remedy, support, compensation and justice through competent authorities or specialist organisations as appropriate.
  

5. Risk Assessment and Supply Chain Due Diligence
Day-Impex undertakes regular supplier and service-provider risk assessments and reviews. Risk assessment is proportionate and considers, where relevant:

• Geographic location and country risk.
• Industry sector and type of manufacturing or service activity.
• Nature and origin of goods, materials or services supplied.
• Use of subcontractors, temporary workers, agency labour or migrant labour.
• Recruitment methods and use of recruitment agencies or labour providers.
• Complexity and visibility of upstream supply-chain tiers.
• Previous audit findings, complaints, adverse information or corrective actions.

Due diligence may include supplier questionnaires, annual supplier reviews under the ISO 9001 QMS, certification and document checks, contractual requirements, desktop research, requests for evidence, risk-based audits and corrective action plans. Higher-risk suppliers are subject to enhanced due diligence and more frequent review where proportionate.
Day-Impex will maintain records of material risk assessments, evidence reviewed, decisions taken and corrective actions. Supplier risk will be reconsidered when there is a significant change in geography, product, ownership, recruitment model, subcontracting, credible allegations or other relevant circumstances.

6. Procurement and Purchasing Practices
Modern slavery risk will be considered across the procurement lifecycle, including needs identification, requirement definition, supplier or tender evaluation, contract award, in-life contract management and end-of-contract review. The level of control will be proportionate to the risk of the goods or services concerned.
Day-Impex will also assess whether its own purchasing practices could create avoidable pressure that increases labour exploitation risk. Reviews will consider:

• Unrealistic lead times, urgent changes or short-notice demand.
• Excessive price pressure or pricing that may undermine lawful labour costs.
• Payment terms or delayed payment that could create cash-flow pressure on suppliers.
• Forecasting accuracy, order volatility and production peaks.
• Contract terms, penalties or service expectations that could encourage excessive overtime, unauthorised subcontracting or unsafe labour practices.

Where concerns are identified, Day-Impex will seek reasonable commercial adjustments, improved forecasting, clearer specifications or other proportionate measures to reduce the risk of adverse labour impacts.

7. Supplier Contractual Requirements and Monitoring
Suppliers and contractors are expected to comply with this policy, applicable labour law and equivalent ethical employment standards. For suppliers assessed as higher risk, adherence to Day-Impex modern slavery requirements will be made a contractual condition or incorporated into equivalent purchasing terms.
Higher-risk suppliers may be required to:

• Acknowledge this policy and provide relevant modern slavery policies or statements.
• Provide evidence of recruitment practices, labour-provider due diligence and worker grievance arrangements.
• Confirm that workers do not pay recruitment fees and that original identity documents are not retained.
• Demonstrate lawful working hours, voluntary overtime practices and freedom of association.
• Cascade relevant requirements to subcontractors or upstream suppliers involved in delivering the goods or services.
• Complete corrective action plans within agreed timescales and provide evidence of closure.

High-risk suppliers will be provided with relevant policy information and, where appropriate, a briefing or training on Day-Impex requirements. Day-Impex will monitor compliance through supplier reviews, evidence requests, audits or other proportionate controls.

8. Worker Voice, Representation and Grievance Mechanisms
Day-Impex supports workers' lawful access to trade unions, elected worker representatives or other independent forms of worker representation. Suppliers must not retaliate against workers for lawful representation, collective activity or raising concerns.
Where proportionate to the level of supply-chain risk, Day-Impex will ask suppliers to demonstrate that workers have access to effective grievance mechanisms that are confidential or anonymous where appropriate, accessible without penalty and communicated in a language workers understand. Higher-risk suppliers may also be asked to demonstrate how grievances are acknowledged, investigated, resolved and fed back to workers.
Day-Impex will consider worker feedback, grievance data and other credible worker-voice evidence when assessing the effectiveness of supplier controls. Material findings will be escalated to Senior Management and, where appropriate, the Board.

9. Ethical Recruitment, Labour Providers and Debt Bondage
Day-Impex recognises that recruitment practices can create risks of forced labour and debt bondage. The following safeguards apply to Day-Impex and are expected of relevant suppliers:

• No worker-paid recruitment fees, deposits or unlawful deductions as a condition of obtaining or retaining work.
• Workers receive clear employment terms and understand material conditions of employment before starting work.
• Workers remain free to leave employment in accordance with law and are not tied through debt, threats or document retention.
• Recruitment agencies and labour providers are screened and evaluated where they are used in higher-risk
  activity.
• Higher-risk recruitment agencies or labour providers are monitored for ethical recruitment and hiring practices.
• Any recruitment-related exploitation concern is investigated and, where appropriate, subject to corrective action, reimbursement or remediation.

Where system weaknesses are identified, Day-Impex will require an improvement plan addressing root cause, corrective action, ownership, timescales and evidence of completion.

10. Training and Awareness
Relevant Day-Impex staff, particularly those involved in procurement, supplier management, operations and contract management, will receive modern slavery awareness training at induction and refresher training at least annually or when there is a material change in risk or guidance.
Training is intended to ensure recipients can identify indicators of modern slavery, report suspicions, understand how modern slavery risks should be considered in procurement and undertake proportionate due diligence. Training will include the ILO Forced Labour Indicators, including:

• Abuse of vulnerability.
• Deception.
• Restriction of movement.
• Isolation.
• Physical and sexual violence
• Intimidation and threats.
• Retention of identity documents.
• Withholding of wages.
• Debt bondage.
• Abusive working and living conditions.
• Excessive overtime.

Training will also cover recruitment-fee risk, grievance routes, non-retaliation, escalation, evidence preservation and the principle that immediate termination of a supplier may not always be the safest response for affected workers.

11. Reporting, Investigation, Response and Remediation
Employees, suppliers, workers and third parties are encouraged to report concerns or suspected modern slavery through line management, HR or another designated senior manager, an available confidential/anonymous reporting route, or an appropriate external whistleblowing or law-enforcement channel. Reports made in good faith must not result in retaliation.
Day-Impex applies the following response process to credible reports:

1. Acknowledge the report as soon as practicable and normally within 2 working days.
2. Complete an initial risk triage normally within 5 working days, with immediate escalation where there is a risk of harm, criminal activity or evidence destruction.
3. Escalate material concerns to Senior Management and, where appropriate, the Board and relevant authorities or specialist organisations.
4. Protect confidentiality and prioritise worker safety, preserving evidence and avoiding actions that may increase risk to victims.
5. Require the supplier, where appropriate, to provide a corrective action plan identifying process gaps, root causes, remedial action, responsible owners and target completion dates.
6. Monitor actions to closure and verify effectiveness. Termination or de-listing will not be automatic where a supplier is not complicit and where continued engagement can better protect workers; however, Day-Impex reserves the right to suspend or terminate relationships for serious, repeated or unremedied non-compliance.
7. Where workers have suffered harm, support access to appropriate remedy, reimbursement, compensation, specialist support and justice through the competent channels.
   Suppliers are expected to operate a similar proportionate process for incidents within their operations and supply chains and to notify Day-Impex promptly of material issues affecting goods or services supplied to Day-Impex.

12. Audits and Ongoing Supplier Oversight
Day-Impex reviews suppliers at least annually as part of its ISO 9001 supplier management process. Modern slavery and labour-practice checks are incorporated on a risk basis. Reviews may be conducted by Day-Impex staff and may include document review, supplier questionnaires, certification checks, evidence requests, interviews or site-based audit activity where proportionate.
Where higher risk is identified, Day-Impex may increase the frequency or depth of review, request independent or third-party evidence, carry out an announced or unannounced audit where contractually permitted and proportionate, or require a corrective action plan. Audit findings and corrective actions will be documented and tracked.

13. External Collaboration and Continuous Improvement
Day-Impex will consider proportionate engagement with relevant NGOs, industry bodies, professional associations, customers, suppliers and other businesses to share good practice, improve supply-chain visibility and strengthen prevention and remediation. The level of engagement will reflect the size, risk profile and practical needs of the organisation and its supply chain.
Day-Impex will keep relevant government guidance, ILO materials and reputable labour-risk information under review and will update its controls where a material change in risk or good practice is identified.

14. Key Performance Indicators
Day-Impex will use the following KPIs to measure implementation and progress. Results will be reviewed annually by Senior Management and reported to the Board as part of the statement review:
KPI Target / measure

• Tier 1 supplier review completion - 100% of active Tier 1 suppliers reviewed at least annually.
• Higher-risk supplier due diligence - 100% of suppliers rated higher risk receive enhanced due diligence and a documented decision/action.
• Relevant staff training - 100% of relevant staff complete modern slavery training/refresher within the required cycle.
• Contractual controls - 100% of new higher-risk supplier agreements/terms include appropriate modern slavery requirements.
• Reported concerns - 100% of credible concerns acknowledged and triaged in line with the response process, subject to exceptional circumstances.
• Corrective actions - 100% of agreed corrective actions are tracked to closure or formally escalated.
• Purchasing-practice review - At least one documented review each year of purchasing practices that could contribute to labour exploitation risk.
• Policy communication - Policy made available to all Day-Impex workers and communicated to relevant Tier 1 suppliers.

15. Objectives for the Next 12 Months

• Complete formal Board approval and website publication of the annual statement.
• Embed the KPI framework and retain evidence of annual review and Board oversight.
• Update supplier onboarding and higher-risk purchasing terms to include explicit modern slavery requirements.
• Enhance annual supplier review records to capture labour, recruitment, grievance and worker-rights evidence where relevant.
• Complete annual training for relevant staff using the ILO Forced Labour Indicators and procurement-specific scenarios.
• Document a purchasing-practice risk review and record any corrective commercial actions.
• Develop a proportionate high-risk supplier briefing/training process and track completion.
• Consider appropriate external collaboration with an industry body, specialist organisation or relevant business network.

16. Monitoring and Annual Review
This policy and statement will be reviewed at least annually and sooner where there is a significant legal, regulatory, organisational or supply-chain change. The annual review will consider risk assessments, supplier reviews, training completion, grievance or incident data, corrective actions, purchasing-practice findings, audit results and KPI performance.
Material findings, overdue corrective actions or serious allegations will be escalated to the Board of Directors. The Board will approve the updated annual statement and record the date of approval.

17. Board Approval and Sign-off
This Modern Slavery and Human Trafficking Policy & Statement is submitted for approval by the Board of Directors of Day Impex Ltd. The signed and dated version should be retained as controlled evidence and used for publication and procurement submissions.

Reference Framework

• Modern Slavery Act 2015.
• UK Government guidance on publishing an annual modern slavery statement.
• Cabinet Office PPN 009: Tackling modern slavery in government supply chains.
• International Labour Organization (ILO) Forced Labour Indicators.