Commitment

This is our Statement on Modern Slavery. We are committed to ensuring that there is no slavery, human trafficking, servitude, forced or compulsory human labour, abuse of power over vulnerable individuals, human trafficking or any other form of exploitation as contemplated by the MSA (Modern Slavery Act) in any part of our business or in our supply chain. We welcome the transparency encouraged by the MSA and this statement sets out for the public, our clients, suppliers and employees, the steps that we are taking in this regard.

Our policies at BAS strive for transparent business operations and performance. We adhere to a high set of ethics and values that guide our governance procedures and daily management decisions. To have a long term valuable impact on the social context of all its stakeholders, BAS recognizes that it must be a profitable business operating above and beyond existing ethical and legal standards. As an organization BAS is committed to expanding its operations globally in a sustainable manner for the benefit of its customers, its employees, and the wider communities and environments on which it impacts. The business takes a pro-active approach to its corporate responsibility, which is deeply rooted in its corporate strategy and business decisions.

For example, at the point of recruitment, appropriate checks in accordance with relevant laws are carried out on prospective employees and our HR team works closely with the relevant teams in the local territories to make sure that pay and conditions are appropriately managed. In accordance with our commitment to acting ethically and with integrity in all our business relationships, we intend to implement effective systems and controls to ensure Modern Slavery is not taking place in our supply chains. This will involve ensuring the effective communication and reinforcement of our relevant policies, which give a clear view of the values and principles that underpin all of our work and that we expect all persons involved in our business and supply chain to adhere to. These policies comprise our Anti-Slavery and Human Trafficking Policy (applicable and available to all of our agents, consultants, contractors, employees and temporary workers) and our Supplier Code of Conduct (applicable and available to all of our suppliers).

Supplier due diligence BAS: procures goods and services from suppliers across the world. We select our suppliers with care. In order to identify and mitigate the risk of Modern Slavery in our supply chain we undertake checks / due diligence in connection with Modern Slavery on existing suppliers and prospective suppliers on a risk assessed basis. In respect of existing clients, the outcome of this due diligence allows us to take appropriate steps to manage any risk of Modern Slavery including reconsidering the continued relationship with those suppliers. In respect of prospective suppliers, the outcome of this due diligence informs our decision to include them in our supply chain and, if so, whether appropriate contractual protections are to be included in our agreements with those suppliers to manage any perceived risk of Modern Slavery.

Business Advice Spain (“BAS”), Statement on Modern Slavery, Madrid, October 2020.