At Universal Flexible Packing Limited we strive to maintain a safe, secure and ethically supportive workforce
whilst at the same time ensuring that our staff members are given the full freedom of equal opportunities. This
statement outlines our commitments to being a sound ethically supportive company in which we will totally reject
any forms of modern slavery, human trafficking and adhering fully to the Modern Slavery Act 2015. This
statement is made on behalf of Universal Flexible Packaging Limited and will be our first statement issued which
will outline our efforts to mitigate the risks of such activities.

Equal Opportunities

Here at Universal Flexible Packaging Limited, we will aim to ensure that:

  • No job applicant or employee receives less favourable treatment on the grounds of his or her race,
    nationality, ethnic origin, religion, philosophical belief, sex, sexual orientation, disability, age, marital
    status, part-time working, promotion or to be a member within a trade union.
  • No applicant or employee is place at any disadvantage on the above grounds that are not justifiable in
    law under the relevant legislation.

If you as a staff member believe that you have been disadvantaged due to any of the above, please do not
hesitate to report this matter immediately to either your Line Manager or the HR Manager so that the issue can
be fully investigated and hopefully resolved.

If you have a disability which would be identified under the purposes of the Equality Act 2010 (the Disability
Discrimination Act 1995 was repealed and replaced by the new act), please contact your Line Manager or the
HR Manager immediately so that reasonable adjustments can be considered for your wellbeing.

The company do not and will not tolerate any forms of discrimination at either of our packaging sites and any
employee whom is found to be acting in such a fashion that would breach this statement will face disciplinary
action that could include dismissal. Every employee has a duty to report any such behaviour to a member of the
senior management team if any instances are noted. The company will actively promote non-discriminatory
behaviour and will not tolerate any such instances which could be considered as unlawful or is covered under
the above examples.

Modern Slavery – Initial Statement

At Universal Flexible Packaging Limited, we recognise that modern slavery is a growing global and local issue,
and the important role that we can play in helping to eradicate such actions from our society. We are working
closely with local authorities, StrongerTogether, SMETA to ensure that our approach is robust and in-line with
best practice.

We believe in treating people fairly and have a zero-tolerance approach to any forms of modern slavery or child
labour. To date, there have been no instances of modern slavery or child labour which have been raised within
our business. Through the steps we already take within the business, we believe that we have a low risk of
modern slavery within our business – this year we are focussing on training, upskilling our employees and
raising the awareness of the modern slavery and child labour issue throughout or company. We shall continue
to vigilant, keep our approach under constant review and to adapt an action plan where necessary.

Modern Slavery – Strategy & Governance

Our strategy of mitigating against modern slavery and child labour is structured around five key areas noted
blow in the pie chart. The remainder of this document covers each of these segments in detail:

Our approaches are aligned with our regard for best practice, including guidance from the home office, HR
Manager, StrongerTogether and SEMTA. We are fully committed as a business to our responsibility to respect
human rights as set out in the International Bill of Human Rights and the International Labour Organisation
Declaration on Fundamental Principles and Rights at Work. We also seek to act within accordance of the United
Nations Guiding Principles on Business & Human Rights.

Our modern slavery and child labour group includes a dedicated team of senior management with the training
and support needed for all of our employees. The following senior management are members of our unique
modern slavery and child labour working group:

  • Tinku Durrani – Company CEO
  • Richard Neil Rudd – Group Technical Manager and Health, Safety & Environment Manager
  • Annie Rossell – HR Manager
  • Tony Scanlon – Group Operations Manager

Our company strategy is to totally eradicate any forms or possibilities of modern slavery and child labour whilst
ensuring that our processes remain effective and appropriate to the business. This will include representation
from the HR Manager, Health, Safety & Environment Manager, Operational Manager and our legal entities. The
modern slavery team will ensure that they meet at least on an annual basis (preferably within our senior
management review or health, safety & environment meetings) to discuss any threats, considerations and
reports of any actions which may indicate a modern slavery network in operation. From a HR perspective, the
HR Manager shall ensure that all employees are:

  • Appropriately screened so that their names, addresses and personal identification are all accurate
  • All employees complete a home office Right to Work form
  • Monitor bank accounts in line with GDPR requirements so that each employee has a different bank or
    banking account number for payment

Below is the structure of how our governance system operates and the procedural flow that our business would
implement:

1. Company Values, People & Policies

Our company values and policies are the foundation of how we operate as a business. They apply to all of our
employees whom are employed by or acting on behalf of Universal Flexible Packaging Limited and includes
contractors, temporary staff members and our approved supply chains for packaging or raw materials. During
2019 – 2020, our company has undertaken the following actions:

  • Updated our company policy and statements to include all aspects of modern slavery, child labour,
    human trafficking to reflect a zero-tolerance approach.
  • HR management to implement further home office checks using the Right to Work form
  • Internal audit due diligence
  • Promote ‘Doing the Right Thing’ company wide and ensuring that our policies are easily accessible to
    all employees, contractors, approved suppliers and even our customers to show our dedication.
  • For beyond 2020 continue to improve our systems, audits and training to include seminars on modern
    slavery developments, StrongerTogether and SMETA audits.

We promote and encourage the use of our company values and especially the ethos to ‘Do the Right Thing’ in
both our working practices and to one another. Each year, our values are reviewed and approved by our senior
management team during our senior management annual meeting – it sets the tone and vibrancy of our
organisation and forms the goal for us to ‘Act with Integrity; as a central core of our business strategy. Our zerotolerance
approach to modern slavery and child labour activities echo across our company and HR policies
which are annually reviewed to include ‘Doing the Right Thing’. Our company also encourages a whistleblowing
procedure for which any staff member can use in cases of fears of physical or mental violence without having to
divulge their identity. Our whistleblowing procedure and policy is safe, confidential and also includes independent
helplines to call which are available 24 hours a day, 7 days a week – these helplines can also assist in translation
services.

All types of whistleblowing, modern slavery or child labour concerns are taken with extreme seriousness and
shall be investigated fully with all findings and documentation regularly reported directly to the senior
management team and the HR Manager.

The effectiveness of our company whistleblowing procedure is reviewed on an annual basis by a ‘challenge test’
and has been agreed as integral as part of our commitment to adhering to the BRC version 8 standard.
Our HR department are committed to setting out and promoting our policies and procedures to ensure that all
of our employees are treated fairly, to protect their human rights and to recruit new staff members (where
required) in line with the requirements of the Modern Slavery Act 2015. Due to the nature of our business, we
feel that our overall risk of modern slavery and child labour within our workforce is low and we can confirm this
with the compliance checks that we have in place before and after commencing employment. At present,
Universal Flexible Packaging Limited employees are employed in permanent contracts within offices, warehouse
and our packaging halls whereas any temporary staff that maybe required is usually at a minimal requirement.
However, due to the majority of our employees working within the production area of the business, these two
thirds of our workforce would present a higher risk of modern slavery.
As part of our recruitment policy, the HR Manager shall conduct thorough compliance checks for all new
employees which would include temporary staff where required. These include, but are not limited to:

  • Home Office Right to Work
  • Criminal Convictions
  • Professional qualifications and education
  • Occupational health (as part of our HSE / TACCP risk assessment and equal opportunities policy)

As previously mentioned in this document, for permanent employees our HR Manager may wish to conduct
further checks which may help to further eliminate the risks of modern slavery and child labour by, for example,
checks on multiple address and bank accounts. By passing these checks as a prerequisite to an offer of
employment, this will present the HR manager with added security that this would be a suitable employee.
Currently, our company prefers to employee staff in permanent contracts rather than sourcing temporary or
agency staff as this aids the company in training needs and resources which are beneficial to maintaining a
healthy workforce with stability.
The following chart gives an indication of our currently business vigilance on modern slavery & child labour and
sets our 5-year action plan for tackling this activity:

2. Training & Awareness

During 2020 and beyond, the company shall make training and awareness of modern slavery & child labour as
a major priority as part of the business training schedule plan and this shall be carried on into 2021. The raising
of awareness by training will help to focus on the eradication on the risk of modern slavery & child labour via our
employees whom would be acting as our ‘eyes and ear’ wherever they may be – either at work or even within
their social groups. Through a suitable and robust training schedule, the company shall ensure that all
employees are fully aware of the importance of the issue and that they have the confidence to identify and raise
any concerns either direct to a senior manager or by use of the whistleblowing procedure.
Appropriate training will be delivered by a certified trained ‘trainer’ that shall be able to offer in depth information
via a group discussion, modern slavery workshop or by the use of the Socrative Food Safety Culture Plan which
is part of the fundamental clause 1.1 of the BRC version 8 standard. As part of our training schedule for both
sites, the objectives will set out:

  • Helping employees to identify modern slavery and child labour activities
  • Understanding the potential risks to Universal Flexible Packaging Limited and how these can be
    managed by the modern slavery team
  • How to report concerns – direct to senior management or via the whistleblowing procedure

Communication is a key aspect of raising the awareness of modern slavery and in many cases, this is where
the courage arises to face those directly that are involved in these activities. By using training and procedures
such as whistleblowing to give extra safety and confidentiality to our staff members, we hope that any risks of
modern slavery to Universal Flexible packaging Limited would be removed. We are also committed to adding
this process monitoring via our DOR, WOR and senior management annual meetings as a top priority to manage
employee safety. There is also encouragement and commitment from our senior management team to helping
with communication and discussing approaches with staff members making sure that they are comforted, and
appropriate authorities are contacted for further support. As part of our approach to training, communication and
commitment, the company shall make special note of the Anti-Slavery Day on 18th October in which revisions
of training and policies will be delivered to the company. We will also encourage all employees to wear purple
clothing as part of our solidarity and observance of this very important date.

3. Approved Suppliers

Our company deals with various approved suppliers for our packaging and also for raw materials in
manufacturing within the United Kingdom and further afield to countries such as Lithuania, Turkey and India.
Currently, we believe that our higher risk suppliers or service providers are with chemical providers, waste
management and external packaging goods. A key focus within our company over the next 5 years will be to
continue to understand the risks further and to take a thematic approach to understand these sectors that present
the higher risk and to work collaboratively with these suppliers. Under our approve supplier procedure and
questionnaire, our company would require service providers and suppliers to issue their statement or policy on
modern slavery so that we are aware that these suppliers are taking their own actions to help eradicate these
practices.
We will encourage all of our suppliers and service providers to join us in our collaboration end stopping modern
slavery & child labour and will proudly make our clients fully aware that this is an activity that we take very
seriously to eradicate as a business. Our continuing work and due diligence for supplier approval will incorporate:

  • Supplier evaluation and only GFSI / BRC approved
  • Evidence of an ethical audit such as SMETA or FastForward (StrongerTogether)
  • Site risk assessments, preferably TACCP
  • 3-year company reviews in line with BRC standards
  • Site audits to suppliers that are deemed a higher risk of modern slavery, if required

4. Risk Assessment

Universal Flexible Packaging Limited are committed to reviewing our ethical, health, safety & environmental risk
assessment processes annually to ensure we can effectively identify actual or potential high-risk areas within
the business and respond accordingly. Our risk assessment process is professionally structured to include
severity of the risk versus the likelihood of the event and are scored according to the risk. All assessments will
be completed and reviewed by a competently trained risk assessor or by the Health, Safety & Environment
Manager whom will then relay all results to senior management meetings for implementation of any actions. Our
risk assessments will follow specific indicators and guidance, and this can be located at various information
sources such as StrongerTogether, SMETA or via the gov.uk website where the Modern Slavery Act 2015 can
be referenced. Further indicators are:

  • Country of operation or origin
  • Type of labour used
  • Services or goods provided
  • Quality of the Modern Slavery Statement
  • Confidence factor applied based on information available from external management

Our risk assessments will be in a continuous development over the next 5 years so that legislation, training
frequencies, alterations to the workforce or changes to the Act are taken into account – these will also be raised
during the senior management commitment objective plan which is completed at the beginning of each year.

5. Progress Evaluation

Key Performance Indicators (KPIs) will help us to monitor and report on the effectiveness of our policies,
procedures and our actions to further mitigate against modern slavery & child labour. We will review these at
least on an annual basis in line with our senior management commitment and health, safety & environmental
awareness. As part of our commitment, our company shall implement the following KPIs so that we can
demonstrate our solid commitment to upholding our modern slavery & human trafficking statement:

  • %(1) of approved suppliers whom are compliant with the Modern Slavery Act 2015 or the Equality Act
    2010
  • Number of speak-up allegations reported within Universal Flexible Packaging Limited relating to modern
    slavery either directly to a senior manager or via our whistleblowing procedure
  • %(1) of management team members attending a modern slavery workshop or seminar annually
  • %(1) of those trained in modern slavery now feel confident or have confidence to recognise and raise
    modern slavery concerns

Modern Slavery – Final Conclusion

We are very proud of the steps that we have taken this year to mitigate the risk of modern slavery within our
business and that our future training commitments will give a strong message to any individuals that would
attempt to conduct any such acts of modern slavery or child labour within this company. Our senior management
team actively encourage all staff members, visitors, auditors and contractors when based at either packaging
site to notify us immediately upon identifying any evidence no matter how small of the observation. We are
clearly setting out an absolute zero tolerance position within our company and will be open and transparent to
our employees as well as our approved suppliers at how we manage to avoid the risks of modern slavery. We
shall invest in training, raising awareness, invite staff to attend modern slavery workshops, complete ethical
audits with a target of <10 non-conformances such as FastForward and SMETA whilst also creating the right
culture throughout the business via our Food Safety Culture Plan.

Our values and the constant changing nature of the packaging industry will create difficulties in the future when
tackling modern slavery & child labour as activities will always be changing and evolving to circumvent our
safeguards, but the modern slavery team at Universal Flexible Packaging is wholly committed to maintaining
our principles and to promote our solid stance against the activities of modern slavery and child labour locally
and beyond.

For any further questions related to our approach of modern slavery & child labour, please feel free to e-mail:
richard.rudd@uniflex.co.uk or annie.rossell@uniflex.co.uk

Working Conditions – Health, Safety & Hygiene

The company shall ensure that our employees are able to work in a safe environment, free from harassment,
bullying or victimisation bearing in mind the prevailing knowledge of the industry and of any identified hazards.
Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or
occurring during the course of work by minimising so far as is reasonably practicable, the causes of hazards
inherent within our working environment.

Our employees shall receive adequate training to include instructions within the areas of Health, Safety,
Environment, Fire, Personal Hygiene, COSHH, HACCP and a full Induction Pack process. These shall be
delivered within a 6-week period of the commencement of employment. Our employees will also be given access
to clean toilet facilities and drinking water and if appropriate, sanitary facilities for food storage will be provided.

If any accommodation for our employees, auditors, visitors or contractors is provided by our company, then we
shall ensure that the facilities provided will be clean, safe, meet basic needs for the worker and to be
appropriately rated at a minimum of 3 stars.

The responsibility of company health, safety and environmental awareness shall be for all employees to observe,
but the Group Technical Manager for the company (Richard Neil Rudd) shall be the delegated coordinator for
the business. He will be a direct contact for any issues raised, conduct risk assessments and shall gather
appropriate information in the maintenance and support for health, safety & environmental issues.

First Aid and Fire suppression equipment shall be made fully available at both packaging sites for which shall
be well maintained, calibrated (where required) and also have trained personnel in emergency first aid and fire
warden duties. All employees will also be provided with appropriate personal protective equipment (PPE) for
their duties and to fall in line with current HSE and COSHH risk assessments.

National Living Wages

The company shall maintain and secure that our employees are paid and benefit from the government
requirement that national minimum wages are paid. This will include a standard working week is met at a
minimum, national legal standards or industry benchmarks are met – whichever is higher. All workers shall be
provided with written and understandable information in regard to their employment in respect to wages,
contracts and the particulars of their wages or salary for the pay period in concern. This information may also
be translated into the employee’s native language if required.

Any deductions from salary or wages either as a disciplinary measure or for absence shall not be permitted nor
shall any deduction from salaries or wages not provided for by national law be permitted without expressive
permission of the employee concerned. Any disciplinary measures will always be recorded, and records
maintained in accordance with the company employee handbook.

Any overtime payments shall be appropriately calculated at the premium rates as legally required and under
GDPR observance. Where a premium or agreed rate is not legally specified, a minimum of the hourly
compensation shall be paid to the employee. Also, any benefits, deductions or withholdings must be
appropriately calculated and documented by the HR Manager.

Excessive Working Hours

Working hours will comply with national laws and benchmark industry standards, whichever afford the greater
protection to the employee and their welfare. In any event, employees shall not on a regular basis required to
work in excess of 48 hours per week and shall be provided with at least 1 day off for every 7-day period on
average. Any overtime shall be voluntary and shall not exceed 12 hours per week – there shall also not be a
demand on a regular basis and there will always involve compensation at a premium overtime rate as agreed
by the company CEO and HR Manager.

Pregnancy, Maternity & Paternity

The company shall fully uphold maternity and paternity rights in accordance with current United Kingdom
legislation. Also, pregnant employees will not be discriminated against their condition and pregnancy shall be
included in all risk assessments where an employee could be at risk of injury to themselves during their
pregnancy. If an employee has any concerns, they are encouraged to speak directly with their Line Manager,
HR Manager or Health, Safety & Environment Manager for further advice.

Employment Provisions

To every extent possible, work performed must be on the basis of a recognised employment relationship which
has been established through national laws and practices. Any obligations to workers under labour and social
security laws and regulations arising from the regular employment relationship shall not be avoid via the use of
labour-only contracting, sub-contracting or home-working arrangements – an inclusion to this policy shall also
be any apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor
shall any such obligations be avoided through the excessive used of fixed-term contracts of employment.

Inhumane Treatment

All forms of physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal
abuse shall not be tolerated at any stage of employment. Any forms of intimidation or discrimination, especially
towards employees with mental health issues will also not be tolerated in any stance. Universal Flexible
Packaging Limited are committed to supporting those with mental health difficulties where practical and further
information may be obtained from the Health, Safety & Environment Manager for guidance.