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Modern Slavery Act

Broadlight Global Ltd recognises that all organisations have an obligation to prevent slavery and human trafficking. Modern Slavery is an international crime affecting millions of people across the globe. It is an unacceptable practice involving people regardless of age, gender or ethnicity in developed (including the UK) as well as developing countries.

Within the UK, victims include people trafficked from overseas, or vulnerable people from the UK, who are forced to work illegally or against their will.As a services organisation where most of our workers are highly skilled and directly employed by our organisation, we consider the risk of modern slavery within our own organisation to be low. However, in order to operate efficiently and provide reliable services for our clients, we work with third parties, such as suppliers and contractors.

We recognise that removing modern slavery entirely from the supply chain presents challenges for many businesses such as Broadlight Global Ltd.The purpose of this statement is to satisfy part 6 of the Modern Slavery Act and to provide an update on our commitment to ensuring that our supply chains are free from slavery and human trafficking.

1. Organisation's Structure.
We are a next generation IT service company delivering business-critical strategic IT projects in the Information Technology and Services sector. Broadlight Global was founded in 2019.

Our Supply Chains Our supply chains include:
- Suppliers of IT equipment, software and services
- Professional services from lawyers, consultants, accountant
- Office cleaning and other office management services
- Marketing and other PR services
- Print and promotional material production
- Training organisations and venues.

2. Our Policies Relating to Slavery and Human Trafficking.
We are committed to ensuring, that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Modern Slavery Act Policy reflects our commitment to acting ethically and with integrity in all our business relationships and through contractual term s we ensure that our suppliers are uphold to the same obligations and high standards so that slavery and human trafficking is not taking place anywhere in our supply chains.

This Anti-Slavery Statement and its practical effectiveness is reinforced by several existing and aligned Broadlight Global Ltd training information and policies, which include:

- Code of Conduct in which we provide the general foundation for how we conduct our business. It declares that board members and employees are obliged to comply with both applicable laws and regulations in the performance of their duties, and in accordance with good business practice, values and ethical guidelines when carrying out their work.
- Anti-bribery and anti-corruption policy to prevent bribery and corruption as well as ensuring compliance with national and international rules. We do not tolerate any bribery or corruption and we condemn it in all form s and we are committed to doing business in compliance with the policy and with integrity.
- Whistle-blow er system in which employees, members of the Executive Board and Board of Directors, auditors, lawyers,suppliers and other business partners of the company can report serious offences or suspected serious offences. Reports may be submitted anonymously, and they are investigated by an external law firm.
- Our core values and ethical guidelines that make us a people-oriented workplace with strongly rooted human rights approach. Our expectation of being an inclusive and equality supporting organisation is guided by the United Nations'Declaration of Human Rights. Through our Code of Conduct training, policies and engagement with our employees, we regularly cover key topics of importance to the company and our employees, such as non-discrimination and protection against harassment.
- Through our Code of Conduct and related anti-corruption activities, we support the UN Global Compact anti-corruption tenth principle.

3. Due Diligence Process in Relation to Slavery and Human Trafficking.
Broadlight Global Ltd is committed to responsible supply chain management and its objective is to com ply with applicable laws and regulations and strive for best practice with regard to responsible supply chain management. Broadlight Global Ltd does not tolerate slavery and human trafficking and will not knowingly engage in, or deal or partner with any suppliers who engage in slavery or human trafficking. Broadlight Global Ltd employees are aware of the company's strong stance against slavery and human trafficking.

Broadlight Global Ltd has assessed the risk of slavery and human trafficking in its UK business and the assessment has revealed the risk of modern slavery in our own organisation to below. Our skilled and agile employees have greater control over their careers,and this significantly reduces the risk of modern slavery. We have a range of employment policies that protect and enhance our employee's experience at work. In compliance with English law, our recruitment team s conduct a right to work check on all new joiners. External resourcing is a potential risk area for Broadlight Global Ltd, although the highly skilled, specialist contractors we engage from time to time are at low risk of modern slavery offences.We consider the biggest risk of modern slavery to be outside our organisation.

Our risk assessment has revealed that the highest potential exposure to slavery and forced labour is likely to be in the following areas:
1. Supply chain - Suppliers of IT equipment, software and services.
2. Maintenance of our buildings - carried out by construction and property maintenance third parties.

Broadlight Global Ltd is committed to ensuring that its suppliers adhere to the highest standards of ethics. Antislavery obligations are included in our contracts with suppliers and they are required to confirm that no part of their business operations contradicts these requirements. Any serious violation may lead to termination of the business relationship.

As part of our commitment to identify and eradicate slavery and human trafficking from within our organisation and from those businesses with which we interact, over the past 12 months we have:
- Continued to ensure that our values and ethics are embedded across our business, in the way we interact with our clients, our employees and our suppliers.
- Continued to encourage the reporting of concerns and the protection of whistle-blowers.
- Rolled out our Code of Conduct to all new joiners to the company.
- Begun to build long-standing relationships with suppliers and to make clear our expectations of ethical business behaviour from them.

In 2020 we will:
- Review our supplier engagement processes by the end of our 2021 financial year to ensure continued compliance.
- Roll out anti-slavery policy as part of staff training to raise awareness of modern slavery across our employee population.

4. Our Effectiveness in Com bating Slavery and Human Trafficking In order to assess the effectiveness of the measures we have taken we will continue to review the following key performance
indicators:
- The number and nature of incidents reported via our whistle-blowing system.
- The number and nature of major and minor non-compliances reported to the Human Resources.
- The number and nature of incidents reported through our internal incident reporting mechanisms in relation to our suppliers.
In 2020 Broadlight Global Ltd:
- Received no reports of breaches through the whistle-blowing system.
- Has had to take no remedial actions in relation to modern slavery or human trafficking.
- Has received no notifications of violation of the supplier code of conduct by any of our existing suppliers.

Further improvements are being made to our processes and procedures in the coming 12 months to improve Broadlight Global Ltd policies relating to modern slavery and to better understand the Broadlight Global Ltd global supply chain and the modern slavery risks we are exposed to.This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes Broadlight Global Ltd slavery and human trafficking statement for 2020.Transparency statement was reviewed and approved by Board of Directors for Broadlight Global Ltd on 11 November 2019.

Signed for and on behalf of Broadlight Global Ltd
Alex Higgins, Director of Broadlight Global Ltd

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