Modern Slavery and Human Trafficking Statement

Introduction
The Broadstone Group of Companies (the Company) has a zero-tolerance approach to modern slavery and human trafficking. We are fully committed to preventing slavery and human trafficking in all our corporate activities.

This statement sets out the actions that we take to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking on an ongoing basis. This statement applies to all business within the Company and also to third parties with access to Broadstone property, systems or data.

Our business and supply chains
Broadstone is a leading, independent, UK consultancy delivering expert advice to employers, insurers and pension scheme trustees.

We have over 600 employees based in 9 office locations across the UK.

As a UK based professional services company, Broadstone does not operate in an industry where modern slavery is prevalent. Nonetheless, we are committed to working with our clients and suppliers to uphold the same high standards and approach to modern slavery. Our supplier selection includes appropriate due diligence of the supplier’s reputation, respect for the law, compliance with health, safety and environmental standards and where appropriate references.

Policies
The Company operates appropriate policies and procedures for identifying, preventing and reporting slavery and human trafficking including a Whistleblowing Policy, Dignity at Work Policy, Diversity, Equality & Inclusion Policy and Health and Safety Policy and Statement.

Supplier due diligence
Given the nature of our business, we believe that the risk of modern slavery and human trafficking in our supply chain is very low, but we always ensure we undertake appropriate due diligence on all new suppliers as part of our contractual negotiations.

Awareness
The Company provides appropriate awareness of modern slavery issues as deemed appropriate for a business of our size and type.

Ongoing commitment
Broadstone is committed to a workplace free from modern slavery and human trafficking and will therefore not conduct business with any organisation involved in such practices.

This statement covers the financial year ending 30th June 2024 and was approved by the board of Zircon Topco Limited on 27th June 2024.