Modern Day Slavery Statement

Introduction

This statement is published by Valknut Group Ltd ("Valknut Group") pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps we have taken during the financial year 2024 to ensure that modern slavery and human trafficking are not taking place in our business or supply chains.

Valknut Group is an international recruitment and workforce solutions business based in the United Kingdom, with operations spanning South Africa, USA, Asia, Australia, and Europe. We are committed to upholding the highest ethical standards and to acting with integrity in all business relationships.

Our Organisation and Supply Chains

Valknut Group provides specialist recruitment and consultancy services to clients operating in the automation, industrial, aerospace, and facilities management sectors. Our supply chain primarily consists of:

• Candidates and contractors placed with our clients.
• Technology and software service providers supporting our internal operations.
• Professional services firms providing legal, financial, and HR advisory services.
• Office supply and facilities vendors.

As a recruitment business, we have a direct responsibility for the welfare and working conditions of the individuals we place. We take this responsibility seriously.

Policies in Relation to Slavery and Human Trafficking

We have the following policies in place that support our commitment to combating modern slavery:

• Recruitment and Vetting Policy: All candidates are subject to identity verification and right-to-work checks. We do not engage with any individual or organisation involved in labour exploitation.
• Supplier Code of Conduct: We require our suppliers to uphold the same ethical standards that we apply to ourselves, including a zero-tolerance approach to modern slavery.
• Whistleblowing Policy: We encourage all employees, contractors, and business partners to report any concerns about modern slavery or unethical conduct without fear of retaliation.
• Equality, Diversity and Inclusion Policy: We are committed to fair treatment of all individuals regardless of background, nationality, or employment status.

Due Diligence Processes

We undertake the following due diligence activities to identify and manage the risk of modern slavery:

• Conducting right-to-work and identity checks on all candidates prior to placement.
• Reviewing our supply chain to identify suppliers operating in higher-risk geographies or sectors.
• Requiring suppliers to confirm their compliance with the Modern Slavery Act 2015 where relevant.
• Monitoring compliance with the Conduct of Employment Agencies and Employment Businesses Regulations 2003.

Risk Assessment

We recognise that the recruitment sector can be vulnerable to labour exploitation, particularly in relation to lower-skilled, temporary, or international workers. As a specialist technical and engineering recruiter, our placements are predominantly for skilled professionals; however, we remain vigilant and apply thorough vetting processes across all placements.

We assess risk based on the nature of the work, the geography of operations, and the vulnerability of the workforce. We have not identified any confirmed instances of modern slavery within our operations or supply chains during the reporting period.

Training and Awareness

We provide awareness training to our employees on the risks of modern slavery and how to identify and report potential indicators. All new employees receive induction training that includes reference to our obligations under the Modern Slavery Act 2015.

Key Performance Indicators

To measure the effectiveness of our actions, we monitor:

• Completion rates for employee modern slavery awareness training.
• The number of right-to-work and identity verification checks completed.
• Any concerns or reports raised through our whistleblowing channel.

Approval

This statement has been approved by the Board of Directors of Valknut Group Ltd and is reviewed annually.