1. Introduction

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (the “Act”) and sets out the steps that Wave Talent has taken to minimise the risk of modern slavery or human trafficking taking place in any part of its business or supply chain.

Wave has a zero-tolerance approach to modern slavery and human trafficking and is committed to ensuring that there is transparency throughout its business. We require the highest standards of integrity from all of our clients, contractors, and business partners.

This statement has been approved by the Wave’s Board of Directors and will be reviewed on an annual basis.

2. Our Policies and Procedures

Wave has the following policies in place which reflect its commitment to acting ethically and with integrity in the course of its business:

• Anti-Slavery Policy - Clearly defines Wave's stance on the Act and outlines supply chain risk evaluation criteria. Provides details on reporting suspicions and training.
• Supplier contracts - We notify all our business partners about our Modern Slavery Policy and conduct thorough due diligence on new suppliers. We also require all our suppliers, through contractual provisions, to confirm that they do not participate in any activities prohibited by the Act. Non-compliance will lead to contract termination.
• Recruitment procedures - Wave has well-established procedures in place for conducting thorough investigations on potential employees. This encompasses verifying their eligibility to work, confirming their residency status, and conducting comprehensive checks on their background and employment history.
• Whistleblowing Policy - This policy allows employees to confidentially raise concerns regarding Wave's activities, without fear of retaliation or mistreatment. Any issue brought up under this policy will be promptly, thoroughly, and confidentially investigated.
• National minimum wage - Wave acknowledges and ensures that no staff member is paid less than the current prevailing rates of the National Minimum Wage.
• Other employment policies - Wave has implemented a wide range of internal policies to ensure a safe and harmonious work environment where all employees are treated fairly and respectfully. These policies cover areas such as Anti-Bribery & Anti-Corruption, Bullying & Harassment, Equity, Diversity & Inclusion, Conduct Rules, and Professional Standards. Wave also acknowledges the Unite Trade Union as the representative body for staff interests.

3. Monitoring

Wave regularly evaluates its policies, procedures, and suppliers to detect any potential risks related to modern slavery and human trafficking. The objective is to ensure that these risks are closely monitored and to establish suitable measures to mitigate each risk to an acceptable level. The Modern Slavery Policy will be reviewed annually by Wave.

4. Staff Awareness

To ensure a comprehensive comprehension of the risks associated with modern slavery and human trafficking in Wave and its supply chain, staff members receive regular updates on Wave's Modern Slavery Policy and undergo training to enhance their understanding.