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Slavery Statement

Modern Slavery Act 2015 Statement

We recognise that effective policies are crucial for combating Modern Slavery. We have an Anti-slavery and Human Trafficking Policy in place that sets out our overall approach to Modern Slavery at Village. We are committed to ensuring we are not supplied by anyone who engages in human trafficking and modern slavery.

Our Right to Work Policy and Recruitment Policy are followed to ensure, as far as possible, that migrant workers are not exposed to exploitation and that the business is not exposed to the fraudulent recruitment of employees.

We also operate a Whistleblowing Policy aimed at employees which encourages staff to report any wrongdoing. We intend to extend this policy to our wider supply chain. General Counsel has overall responsibility for our Modern Slavery policies.

RISK MONITORING AND COMPLIANCE

In order to identify and address risks of Modern Slavery in our supply chain we have:

Carried out a first tier risk supplier mapping exercise in order to identify suppliers that fall within an area that is at high risk of Modern Slavery, and we have addressed Modern Slavery with these suppliers by requesting copies of their policies and procedures and advising them that there will be an audit trail in place over the next year for dealing with compliance.

Addressed Modern Slavery as a formal business risk and put in place a mitigation plan that will be reviewed at quarterly meetings and owned by Heads of Departments within the business who will manage those mitigation plans.

Reviewed our procurement processes to identify Modern Slavery as a risk to be identified and assessed on supplier audits.

Ensured the Right to Work policy is followed with strict compliance.

Reviewed our policies on Modern Slavery with a view to identifying the additional policies and codes of conduct that need to be put in place and which are identified in the next steps for 2017 / 2018.

Modern Slavery Act 2015 Statement

NEXT STEPS

Following a review of the effectiveness of the steps we have taken to date to ensure that we are identifying and combating Modern Slavery in our business or supply chains, we intend to take the following further steps to combat Modern Slavery during 2017 / 2018;

Put into place a supplier code of conduct and an employee code of conduct which will clearly set out our approach to Modern Slavery and communicate to the wider business and to our suppliers how it can be identified and how we intend to deal with it.

Produce quarterly reports to the Board assessing the risks from suppliers, employees and any other areas which could be affected by Modern Slavery and ensure mitigation plans are updated and actions identified are addressed.

Provide wider training to the business including the launch of a Modern Slavery Awareness Programme. Such training shall be integrated into both induction and on-going learning for employees.

Develop a more detailed process for our second tier suppliers in order to assess their risk of Modern Slavery in providing goods and services to our business.

Review our recruitment process with the intention of ensuring Modern Slavery cannot infiltrate our business.

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