Modern Slavery Statement

MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

Introduction

This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 05 December 2021.

Max Emerald Ltd (‘the Company’, ‘we’, ‘us’ or ‘our’) is committed to preventing slavery and human trafficking violations in

its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values.

Organisational structure

Max Emerald Ltd has business operations in the United Kingdom.

We operate in the Recruitment & HR , Business consultancy, health and social care , sector. The nature of our supply chains is as follows: We provide highly and professionally trained and well checked workers to private and public organisations including specialist healthcare workers , recruitment of international students to colleges and Universities in the Uk and general business consultancy .

For more information about the Company, please visit our website: www.maxemerald.com.

Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include the following:

Recruitment and selection policy – We adopts transparent ,robust recruitment procedure which include immigration checks .

Ensuring candidates have the correct right to work status & documents Appropriate clearance is obtained (via DBS,PVG &access NI respectively) Candidates are appropriately trained (including safeguarding adults & children ) Appropriately trained office staff

Policies & procedures in place .

Whistleblowing policy – We operate this policy so that employees are able to raise concerns about how staff are being treated or practices within our business or our supply chains without fear of reprisal.

Safeguarding policy – This policy highlights the potential risks of modern slavery and human trafficking, including how to identify signs of exploitation and how to report concerns.

Duty of Candour policy – We operate this policy to ensure we are open & honest about every unintended or unexpected incidents to those affected while delivering our duties that such incidents have occurred; apologise and involve them in meetings about the incidents, review what happened with a view to identifying areas for improvement and learning .

We make sure our suppliers are aware of our policies and adhere to the same standards.

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:

Internal supplier audits.

Our due diligence procedures aim to:

Identify and action potential risks in our business and supply chains.  Monitor potential risks in our business and supply chains

Reduce the risk of slavery and human trafficking occurring in our business and supply chains.  Provide protection for whistleblowers.

Risk and compliance

The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through:

Reviewing on a regular basis all aspects of the supply chain based on supply chain mapping.

We do not consider that we operate in a high-risk environment because the majority of our supply chain is based in the UK and in low-risk industries, such as internet software and services .

We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will require that supplier to remedy the non-compliance.

Effectiveness

The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. These KPIs are as follows:

We will train our staff about modern slavery issues and increase awareness within the Company. We will carry out a regular audit of suppliers – 100% of suppliers each year.

Training our staff

The Company requires its staff to complete training and ongoing refresher courses on slavery and human trafficking. The Company’s training covers:

How to identify the signs of slavery and human trafficking.

What initial steps should be taken if slavery or human trafficking is suspected.

How to escalate potential slavery or human trafficking issues to the relevant parties within the Company. What external help is available.

What steps the Company should take if suppliers in its supply chain do not implement anti-slavery policies in high- risk scenarios, including their removal from the Company’s supply chain.