Statement

Modern Slavery & Human Trafficking Policy and Statement

Introduction

Amer Logistics Ltd t/a Johnsons (“the Organisation”) is committed to preventing modern slavery, human trafficking, forced labour and exploitation in all aspects of its operations and supply chain.

We recognise our responsibilities under the Modern Slavery Act 2015 and adopt a zero-tolerance approach to all forms of modern slavery. This policy sets out the systems, controls and governance arrangements we have in place to identify, prevent, mitigate and respond to modern slavery risks.

In line with best practice, this policy has been developed in alignment with BS 25700:2022 – Organisational Responses to Modern Slavery. Our approach is both risk-based and human rights-centred, recognising that modern slavery is not solely a compliance issue but a risk to people. Accordingly, we place the protection, dignity and wellbeing of workers at the core of our decision-making and operational controls.

This document constitutes both our Modern Slavery Policy and our Transparency Statement in accordance with Section 54 of the Modern Slavery Act 2015.

Context of the Organisation

The Organisation operates within labour-intensive sectors, delivering commercial and domestic removals, laboratory logistics, office installations and associated services across the United Kingdom, Ireland and the world. These activities require a flexible and responsive workforce model, which can involve the use of agency labour, subcontractors and specialist providers.

We recognise that this operating model, alongside broader external factors such as labour market pressures, workforce mobility and varying regulatory environments, can present an increased risk of modern slavery. In particular, the use of temporary labour, multi-tiered supply chains and time-sensitive service delivery can reduce visibility and increase vulnerability if not appropriately managed.

Internally, our governance structures, operational controls and people management practices are designed to mitigate these risks. Externally, we acknowledge the expectations of our clients, workforce, suppliers, regulators and wider society, and are committed to maintaining our social licence to operate through ethical, transparent and responsible business practices.

Governance and Accountability

The Organisation has established clear governance arrangements to ensure accountability and oversight of modern slavery risks. Ultimate responsibility sits with the Board of Directors, who approve this policy and receive periodic updates on its effectiveness. Day-to-day responsibility for implementation is delegated to the QHSE Director, who acts as the designated Modern Slavery Lead and oversees risk management, policy application and reporting.

This is supported by the HR function, which is responsible for workforce compliance, recruitment practices and employee welfare, and the Supply Chain Manager, who leads on supplier due diligence and monitoring. Modern slavery risk management is embedded within our wider corporate governance framework, including our risk management processes and ESG strategy, ensuring that it is considered as part of strategic and operational decision-making.

Our Policies and Commitments

Our commitment to preventing modern slavery is underpinned by a suite of complementary policies that promote ethical behaviour, transparency and accountability. These include our Whistleblowing Policy, Recruitment and Selection Policy, Supplier Code of Conduct and Anti-Discrimination and Dignity at Work policies.

Collectively, these frameworks establish clear expectations for behaviour across our organisation and supply chain, reinforcing our commitment to acting with integrity and upholding internationally recognised human rights principles. We are clear in our expectation that all individuals and organisations working with or on behalf of us operate to the same standards.

Modern Slavery Risk Management

We adopt a structured and risk-based approach to identifying and managing modern slavery risks across our operations and supply chain. This approach takes into account the nature of our services, the profile of our workforce and the characteristics of our supply chain.

Key risk factors include the use of agency or temporary labour, the potential vulnerability of certain worker groups, the labour-intensive nature of our services and the complexity of supply chain relationships. These risks are assessed and categorised using a defined risk framework, enabling us to prioritise controls and allocate resources proportionately. All identified risks are recorded within our organisational risk register and are subject to periodic review. This ensures that our approach remains dynamic and responsive to changes in our operating environment.

Worker Rights and Protection

We recognise that effective prevention of modern slavery is rooted in the protection and empowerment of workers. We are committed to ensuring that all individuals working within or on behalf of the Organisation are treated with dignity, fairness and respect. We ensure that employment is freely chosen and that workers are able to leave employment without restriction. All workers are provided with clear and transparent terms and conditions, communicated in a language they understand, and are paid in accordance with applicable legal requirements. We operate in line with the “Employer Pays Principle”, ensuring that no worker is required to pay recruitment fees or associated costs in order to secure employment.

We are committed to providing safe working conditions, appropriate welfare facilities and a working environment that supports both physical and psychological wellbeing. We also support freedom of association and recognise the importance of worker representation and open dialogue.

Workers are encouraged to raise concerns and are provided with access to confidential grievance and whistleblowing mechanisms. These channels are available to all workers, including agency and subcontracted labour, and can be accessed without fear of retaliation. We actively promote a culture in which individuals feel safe and supported to speak up.

Recruitment and Employment Practices

Our recruitment practices are designed to ensure fairness, transparency and compliance with legal and ethical standards. We undertake robust pre-employment checks, including right-to-work verification and identity confirmation, and only engage with reputable and vetted labour providers.

We require all agencies and labour providers to adhere to our Modern Slavery standards and to demonstrate that appropriate checks and safeguards are in place within their own operations. This includes confirmation that workers have not been charged recruitment fees and that employment practices are lawful and ethical.

We maintain oversight of recruitment practices and take steps to verify that the conditions under which workers are engaged align with our expectations and legal requirements.

Procurement and Supply Chain Management

Modern slavery risk management is embedded within our procurement and supply chain processes. We take a risk-based approach to supplier onboarding and management, ensuring that appropriate due diligence is undertaken before entering into business relationships. All suppliers are required to comply with our Supplier Code of Conduct, which sets out our expectations in relation to ethical behaviour, labour standards and modern slavery prevention. We assess suppliers based on risk and apply enhanced due diligence where higher risks are identified.

We are committed to responsible procurement practices, recognising that commercial decisions can influence labour conditions within the supply chain. We therefore avoid unrealistic pricing or delivery expectations that may increase the risk of exploitation and instead seek to build transparent, collaborative and long-term supplier relationships. Where concerns are identified, we will engage with suppliers to implement corrective actions. Where necessary, we reserve the right to terminate relationships where standards are not met.

Due Diligence

Our due diligence processes are designed to identify and mitigate risks across both our workforce and supply chain. Within our workforce, this includes right-to-work checks, identity verification, reference checks and ongoing monitoring for indicators of exploitation or coercion.

Within our supply chain, we undertake risk assessments at the point of onboarding and conduct periodic reviews to ensure ongoing compliance. Where higher risks are identified, we implement enhanced due diligence measures, including audits and targeted reviews.

This approach enables us to maintain visibility and control over potential risks and to take proactive steps to address them.

Training and Awareness

We recognise that awareness and understanding are critical to preventing modern slavery. We therefore provide training to employees at all levels, ensuring they are equipped to identify risks and respond appropriately. Training covers the identification of modern slavery indicators, risk awareness within operational and supply chain contexts, reporting procedures and ethical procurement practices. All employees are required to complete training within a defined timeframe, with enhanced training provided to those in higher-risk roles.

In addition to formal training, we support awareness through internal communications, campaigns and engagement activities, reinforcing our commitment to this issue across the organisation.

Reporting, Response and Remediation

We are committed to ensuring that all concerns relating to modern slavery are taken seriously and addressed appropriately. Individuals are encouraged to report concerns through line management, HR or confidential whistleblowing channels, and we ensure that all reports are handled sensitively, confidentially and without fear of retaliation. All concerns are investigated promptly and impartially, with appropriate escalation where necessary. Where modern slavery is identified or suspected, our response is guided by a victim-centred approach that prioritises the safety and wellbeing of affected individuals.

We will take immediate steps to remove individuals from harm and will work with relevant authorities and specialist organisations to ensure that appropriate support is provided. This may include access to advice, safe accommodation and other support services where required.

In addition to addressing immediate risks, we undertake root cause analysis and implement corrective actions to prevent recurrence. This ensures that our response not only addresses individual cases but strengthens our overall control environment.

Measuring Effectiveness

We monitor the effectiveness of our approach through defined performance indicators and regular review processes. These include monitoring training completion, supplier compliance, due diligence activities and the investigation and resolution of reported concerns. Performance is reviewed by senior leadership on a periodic basis, enabling us to assess the effectiveness of our controls and identify areas for improvement.

Continuous Improvement

We are committed to continuously improving our approach to managing modern slavery risks. This includes reviewing our policies and processes, monitoring changes in legislation and best practice, and engaging with industry initiatives and stakeholders. Through this approach, we aim to strengthen our systems, enhance transparency and ensure that our response remains effective, proportionate and aligned with evolving expectations.