Spence Ltd (“we”, “our”, “us”) is committed to preventing modern slavery and human trafficking in all its operations and supply chains. This policy outlines our approach to identifying, preventing, and addressing these risks.

This policy applies to:

• All employees, officers, and directors of Spence Ltd.

• All third parties, suppliers, contractors, and service providers we engage.

• Modern Slavery: Encompasses slavery, servitude, forced or compulsory labour, and human trafficking.

• Supplier: Any third party providing goods or services to us.

• Zero Tolerance
  We have zero tolerance for modern slavery and expect the same from our partners.

• Due Diligence
  We conduct risk-based due diligence on suppliers, including questionnaires and audits for high-risk relationships.

• Training & Awareness
  Employees with procurement responsibilities receive training on modern slavery risks and indicators.

We maintain a risk register covering:

• Geographic risk (operations in high-risk regions).

• Sectoral risk (industries prone to labour exploitation).

• Transactional risk (use of subcontracted or temporary labour).