MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

Introduction

Modern slavery is a heinous crime and a morally reprehensible act that deprives a person’s liberty and dignity for another person’s gain. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chain

Zeus (the “Company”) acknowledges the provisions of the modern slavery act 2015 and will ensure transparency within the organisation and with suppliers of goods and services to the organisation. The Company is satisfied from its own due diligence that there is no evidence of any act of modern-day slavery or human trafficking within our own organisation.

As part of the Company’s due diligence processes into slavery and human trafficking, the supplierapproval process incorporates a statement of compliance.

Zeus have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain. We have taken concrete steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking during the financial year 2020.

Our business and supply chains

Zeus is a packaging solutions provider in Ireland, the UK and various locations around the world inside and outside of the EU

We establish a relationship of trust and integrity with all our approved suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier’s reputation, respect for the law, compliance with health, safety and environmental standards, and references.

We haven’t been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, then we would act immediately against the supplier and report it to the authorities.

Policies

Zeus operates the following policies for identifying and preventing slavery and human trafficking in our operations:

• Whistleblowing Policy – we encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of repercussions
• We provide an open door policy to protect the identity of the whistle-blowers.
• Code of Conduct – our code encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply
• Purchasing Code – we have updated our approved supplier SAQ to make explicit reference to slavery and human

Supplier due diligence

Zeus conducts due diligence on all new suppliers during on-boarding and on existing suppliers at regular intervals. This includes:

• Assessing risks in the provision of particular services
• Auditing the suppliers, and their health and safety
• Requiring improvements to substandard employment
• Sanctioning suppliers that fail to improve their performance in line with our requirement

We require all suppliers to attest that:

• They don’t use any form of forced, compulsory or slave labour
• Their employees work voluntarily and are entitled to leave work
• They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment
• They don’t require employees to post a deposit/bond and don’t withhold their salaries for any reasons
• They don’t require employees to surrender their passports or work permits as a condition of employment

Business Awareness

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we deliver awareness training to all employees, publish our Modern Slavery Policy on the staff intranet, and send regular communications to our staff on business ethics.

Training In addition to the awareness program

Zeus has given advice to staff on:

• Various forms of modern slavery in which people can be held and exploited
• The size of the problem and the risk to our organisation
• How employees can identify the signs of slavery and human trafficking, including unrealistically low prices
• How employees should respond if they suspect slavery or human trafficking
• How suppliers can escalate potential slavery or human trafficking issues to the relevant people within their own organisation
• What external help is available for the victims of slavery
• What terms and guidance should be provided to suppliers in relation to slavery policies and controls
• What steps Zeus will take if a supplier fails to implement anti-slavery policies or control

This statement has been authorised by the board and covers the financial year 01.01.2023 to 31.12.2023

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