Anti-Slavery Policy

Positively You’s Anti-Slavery Policy

Introduction

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that Positively You has taken and is continuing to take to ensure that modern slavery and human trafficking are not taking place within our business or supply chains.

Modern slavery encompasses slavery, servitude, human trafficking, and forced labor. Positively You has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our Business

Positively You is a educational workshop provider and we operate primarily in the UK.

Our Policies

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

• Anti-Slavery Policy – Our anti-slavery policy outlines our commitment to ethical business practices and sets out the responsibilities of all staff in observing and upholding our position on modern slavery.
• Whistleblowing Policy – We encourage all employees to report any concerns related to the direct activities, or the supply chains of the organization. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.
• Code of Conduct – Our code makes clear to employees the actions and behavior expected of them when representing the organization.
• Supplier Code of Conduct – We are committed to ensuring that our suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labor.

Our Supply Chain

Our supply chain includes Schools, Colleges, Universities, corporate companies Printing supplies and stationary suppliers. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes:

• Reviewing their modern slavery policies and statements
• Making enquiries about the reputation of potential suppliers
• Taking steps to improve substandard suppliers’ practices, including providing advice and guidance
• Invoking sanctions against suppliers that fail to improve their performance in line with an action plan, including the termination of the business relationship

Risk Assessment and Due Diligence

We have conducted a risk assessment of our supply chain by taking into account:

• The risk profile of individual countries based on the Global Slavery Index
• The business services rendered by the suppliers
• The presence of vulnerable demographic groups
• A news analysis and the insights of labor and human rights groups

This assessment has helped us identify our highest risk areas, and we are implementing specific measures to ensure we address these areas.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business and our supply chains, we provide training to our staff. All staff are required to familiarise themselves with our Anti-Slavery Policy, and managers receive additional training on identifying and responding to supplier risks.

Our Performance Indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

• No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
• Annual supplier audits reveal no issues of concern.

Approval

This statement was approved by the Board of Directors of Positively You on 16/04/2025.

Signed: Ben Thwaites

Title: Director

Positively You Education Ltd

Date: 16/04/2025