MODERN SLAVERY AND HUMAN
TRAFFICKING STATEMENT

1. 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 30th November 2022.

Capilaux 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 services. We have zero-tolerance towards slavery and require our supply chain to comply with our values.

2. Organisational Structure
Capilaux Ltd (Capilaux) is an international recruitment and marketing business, with a UK based office, providing recruitment services and digital marketing services to those operating in the aerospace and aviation, pharmaceutical and life sciences and legal markets worldwide.

3. 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:
Equality and Discrimination Policy – outlining our own policies and commitment to equality in the workplace.
Speak Up Safely (Whistleblowing) Policy – outlining and encouraging people to come forward and voice their concerns in a responsible and effective manner. We make sure our suppliers are aware of our policies and adhere to the same standards.

4. Capilaux’s Supply Chains
Our supply chains comprise of suppliers who provide goods and services to us, as well as suppliers who are involved in the services we provide to our clients and candidates. Such suppliers consist of other recruitment agencies.

5. Supply Chain Due Diligence
Capilaux aims to work with only those suppliers that demonstrate high levels of commitment to monitoring and reducing the risk of modern slavery and human trafficking taking place within their organisations or supply chains. 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 risk 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.

6. 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 supply chain through:
• Evaluating the slavery and human trafficking risks of each new supplier
• Reviewing on a regular basis all aspects of the supply chain

We do not tolerate slavery and human trafficking in our supply chain . Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will seek to terminate our relationship with that supplier immediately.

7. Effectiveness
The Company uses regular reporting to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. We carry out annual audits of suppliers including contacting them to enquire about their modern slavery practices every year.

8. Training our Staff
The Company requires staff to complete training and annual refresher workshops 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 salary or human trafficking issues to the relevant parties within the Company.