1. Organisation’s Structure, Business, and Supply Chains

CKT Holdings Limited (Trading as Aspire) is a business-to-business supplier based in Northern Ireland. We supply LED Image Panels, Privacy Screens, and Maternity Equipment operating in the Healthcare, Education, Workplace, and general construction sectors in Great Britain, Northern Ireland, and the Republic of Ireland.

We also work with partner manufacturers and suppliers from Great Britain and the Netherlands.

2. Scope

This policy applies to all employees, officers, contractors, suppliers, and other business partners associated with CKT Holdings Limited (Trading as Aspire). It extends to all parts of our business operations and supply chains, regardless of the geographical location or sector in which we operate.

3. Company Commitment

At CKT Holdings Limited (Trading as Aspire), we have a zero-tolerance approach to modern slavery and human trafficking. We are committed to:

• Acting ethically and with integrity in all our business relationships.
• Implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking do not occur within our business or supply chains.
• Complying with all applicable laws and regulations, including the UK Modern Slavery Act 2015.

Additionally, we are committed to protecting the following freedoms and rights of workers:

• Freedom to terminate employment without fear of reprisal, in accordance with applicable notice periods and employment laws.
• Freedom of movement, ensuring workers are not physically restricted or coerced in their movement.
• Freedom of association, allowing workers to form or join unions and engage in collective bargaining in line with local laws.

4. Prohibited Practices

We prohibit any practices that infringe upon human rights and dignity, including but not limited to:

• Threats of violence, harassment, and intimidation against workers.
• Worker-paid recruitment fees, as all recruitment costs should be borne by the employer.
• Compulsory overtime, ensuring that all overtime work is voluntary and compensated fairly.
• Child labour, strictly prohibiting the employment of individuals below the legal working age in all countries where we operate.
• Discrimination, ensuring that all workers are treated equally and without bias based on race, gender, age, disability, sexual orientation, religion, or any other characteristic.
• Confiscation of workers' original identification documents, ensuring workers retain possession of all necessary documentation such as passports or IDs.

5. Our Responsibilities

We recognize our responsibility to ensure that modern slavery is not taking place within our organization or any of our supply chains. To uphold this commitment, we require our suppliers, contractors, and business partners to adhere to the same high standards as we do. This includes:

• Implementing their own policies against modern slavery and human trafficking.
• Training high-risk suppliers on our relevant policies, ensuring they are equipped with the knowledge to prevent modern slavery within their operations.

The risk of modern slavery within our business and supply chains is greatest in our Tier 2 supply chain partners located in China who supply our Tier 1 partners with raw materials and componentry.

6. Due Diligence and Risk Management

We conduct thorough due diligence in relation to modern slavery, including:

• Evaluating potential new suppliers to assess the risk of modern slavery before entering into business relationships.
• Requiring written assurances from suppliers regarding their own anti-slavery practices and processes.
• Providing training and guidance for high-risk suppliers to align them with our standards and expectations.

7. Reporting Concerns

We encourage all employees, contractors, suppliers, and business partners to report any concerns related to modern slavery or human trafficking. Employees should report concerns to their line manager.

All reports will be taken seriously and investigated promptly, and CKT Holdings Limited (Trading as Aspire) will not tolerate any retaliation against individuals who report suspected instances of modern slavery in good faith.

8. Training and Awareness

Training is provided so that all relevant employees are aware of the risks and signs of modern slavery and human trafficking. This training covers:

• An overview of modern slavery and human trafficking.
• How to identify and respond to instances of modern slavery in the workplace and supply chains.
• The responsibilities of employees and management in preventing modern slavery.

Training is mandatory for key personnel involved in procurement, supply chain management, and other relevant areas of the business. Additionally, high-risk suppliers will receive training to help them understand and implement our policies effectively.

9. Monitoring and Review

We will regularly review and update this policy to ensure its effectiveness and alignment with the latest legal requirements and best practices. Any amendments will be communicated to all staff and business partners as appropriate.

The effectiveness of the policy will be measured through:

• Regular reviews of suppliers and business operations.
• Regular reviews of the training and awareness programs.
• The number of reports made and the outcomes of investigations into suspected modern slavery incidents.

CKT Holdings Limited (Trading as Aspire) is fully committed to preventing modern slavery and human trafficking in all parts of our business and supply chains. We will continue to assess and strengthen our policies and processes to ensure compliance with the Modern Slavery Act 2015 and uphold the highest standards of ethical conduct.