Modern slavery statement

Introduction

This statement sets down Enlighten Training & Consultancy Limited's commitment to preventing slavery and human trafficking in our business activities, and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.

Organisational structure and supply chains

This statement covers the business activities of Enlighten Training & Consultancy Limited, which are as follows:

A privately owned training, learning and development company operating largely in the "blue light" emergency services sector, providing online and in-classroom training services through a network of associates.

The Company currently operates in the following countries: United Kingdom.

The Company assesses whether particular activities or countries are high risk in relation to modern slavery or human trafficking through individual assessment of the supply and activity chain at the project scoping stage, identifying the supply chains of materials and associates deployed for completion of a project.

High risk activities

The following activities are considered to be at high risk of modern slavery or human trafficking. None are present in our business or supply chain at the date of most recent review:

• Aggressive pricing that does not consider sustainable production costs
• Short lead times
• Late high-volume orders
• Inaccurate forecasting
• Late or extended payments
• Withdrawal from contracts at the last minute
• Unfair penalties for not meeting orders despite last-minute changes
• Inaccurate technical specifications

We consider these elements of risk at the following stages of contract management:

• Needs identification
• Requirement definition
• Tender evaluation (including scoring and adjudication process)
• Contract award
• In-life contract management
• End of contract review

The Owner and Directors have responsibility for the Company's anti-slavery initiatives as follows:

• Policies are developed by looking at good practice and adapting it to the needs of the company.
• Risk assessments in respect of human rights and modern slavery are undertaken, ranking risks from high to low in respect of priority, given their likelihood and severity.
• Due diligence in relation to known or suspected instances of modern slavery and human trafficking is undertaken.

Training

To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company requires all staff to complete an online training module.

Service level agreement

It is important to have a prompt and victim-centred response to reports of modern slavery, so that victims are safeguarded and supported in receiving justice and compensation.

If alerted to an incidence of potential modern slavery, we will have a plan in place with relevant actions within a 72-hour period. This will include identification of relevant suppliers, who will be required to provide an action plan highlighting gaps in their process, root causes of the incident, and corrective action they are undertaking as a result.

Policies

The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This statement affirms our intention to act ethically in our business relationships.

In our Modern Slavery Policy we enable:

• Adherence to local and national laws
• Freedom of workers to terminate employment
• Freedom of movement
• Freedom of association

In our Modern Slavery Policy we:

• Prohibit any threat of violence, harassment and intimidation
• Prohibit the use of worker-paid recruitment fees
• Prohibit compulsory overtime
• Prohibit child labour
• Prohibit discrimination
• Prohibit confiscation of workers' original identification documents
• Provide access to remedy, compensation and justice for victims of modern slavery

The following policies also set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

• Company Shared Statement of Values — sets down the actions and behaviour expected of employees when representing the Company.
• Corporate Social Responsibility (CSR) Policy — summarises how we manage our environmental impacts and how we work responsibly with suppliers and local communities.

Due diligence processes for slavery and human trafficking

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company's due diligence process includes building long-standing relationships with suppliers, making clear our expectations of business partners, evaluating the modern slavery and human trafficking risks of each new supplier, and invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us — including the termination of the business relationship.

We meet good practice in this policy as:

• Policies are approved by senior management
• Policies are available to workers in our organisation and communicated to them
• Policies are available to workers in our supply chain and communicated to them
• Relevant staff in our organisation are trained on these policies
• High-risk suppliers, while we have none in our supply chain, would be required to adhere to our modern slavery policies as a contract condition
• High-risk suppliers, while we have none in our supply chain, would be trained on the relevant policies

Performance indicators

The Company uses key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains, including requiring all staff to have completed training on modern slavery annually.

This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. The Directors endorse this policy statement and are fully committed to its implementation.