Hermes Parcelnet Limited Anti-Slavery and Human Trafficking policy

14 August 2017

1. Policy Statement

1.1 Modern Slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Hermes Parcelnet Limited (“Hermes”) has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings, relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business and in any of our supply chains.

1.2 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We audit suppliers and service providers, based on risk, for their compliance with our Code of Conduct. We expect the same high standards from all of our suppliers, service providers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether this be adults or children and we expect our suppliers and service providers will hold their own suppliers and supply chains (where relevant) to the same high standard.

1.3 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels.

1.4 This policy does not form any part of any employee’s contract of employment and we may amend it at any time.

2. Responsibility for the Policy

2.1 The board of directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and all those under our control comply with it.

2.2 The Human Resources Director has primary responsibility and the Head of Reward and Corporate Business Partnering (Vicky Connell) day to day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

2.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

3. Compliance with this Policy

3.1 You must ensure that you read, understand and comply with this policy.

3.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

3.3 You must notify your Line Manager and the Head of Reward and Corporate Business Partnering OR use the confidential whistle blowing helpline as soon as possible if you believe or suggest that a conflict with this policy has occurred, or may occur in the future.

3.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

3.5 If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your line manager, the Head of Reward and Corporate Business Partnering OR the confidential

whistleblowing hotline as soon as possible. Where appropriate, and with the safety and welfare of local workers as a priority, Hermes may give support and guidance to their suppliers to help them address coercive or exploitative work practices in their own business and supply chain.

3.6 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chain constitutes any of the various forms of modern slavery, raise it with your Line Manager and Head of Reward and Corporate Business Partnering OR use the confidential whistle blowing helpline.

3.7 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our business or in any part of our supply chain. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Head of Reward and Corporate Business OR the confidential whistleblowing hotline immediately. If the matter is not remedied, and you are an employee, you should raise it formally using Hermes Grievance Policy available

4. Communication and awareness of this Policy

4.1 This policy will be sent out to all new employees as part of their Induction Pack and training on the risk our business faces from modern slavery in its supply chain will be provided as necessary.

4.2 Hermes commitment to the issue of modern slavery in our business and supply chains will be communicated to all suppliers, clients, service providers and business partners at the outset of business relationship with them and reinforced as appropriate thereafter.

5. Breaches of this Policy

5.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

5.2 We aim to work with suppliers and service providers to remediate incidents of non-compliance but, in appropriate circumstances, may terminate our relationship with individuals and organisations working on our behalf if they breach this policy.