This policy explains how Connected Places Catapult (“CPC”) prevents and addresses modern slavery, and how we meet our obligations under the Modern Slavery Act 2015 (“MSA”).

It also sets expectations for our suppliers and business partners, and describes the controls we use to reduce the risk of modern slavery in CPC’s operations and supply chains.

This policy was approved by CPC’s Senior Leadership Team (SLT) in 2026 and will be reviewed annually.

1. What is modern slavery?

Modern slavery is a crime and a violation of fundamental human rights. It includes slavery, servitude, forced or compulsory labour, and human trafficking. These practices involve the exploitation of people and the deprivation of liberty for personal or commercial gain.

Indicators can include (for example) restriction of movement, retention of identity documents, threats or intimidation, excessive working hours, unsafe conditions, or withholding of wages. If you have concerns about Modern Slavery within our supply chain then you should raise them in accordance with the reporting process in section 5.

2. CPC’s approach

CPC has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings and relationships.

CPC is dedicated to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its business or supply chain. Further, it is committed to ensuring there is transparency in its approach to tackling modern slavery throughout the supply chain – consistent with its obligations under the MSA.

CPC expects the same high standards from all of its agents, contractors, sub-contractors, suppliers and their sub-contractors, consultants, third-party representatives and other business partners.

3. Scope

This policy applies to all CPC colleagues and to anyone working for, or on behalf of, CPC. This includes employees, workers, agency staff, secondees, interns/work experience, volunteers, and any third parties (including contractors and consultants) who provide services to CPC or who procure goods and services on CPC’s behalf.

4. Responsibilities

Senior Leadership Team (SLT)
SLT is responsible for approving this policy and for providing oversight of CPC’s approach to tackling modern slavery.

Procurement Team
The Procurement Team has primary and day-to-day responsibility for ensuring that procurement processes are effective in countering modern slavery, including:

• implementing this policy;
• providing an induction process to new starters within the Procurement Team;
• delivering regular training to relevant people in the business;
• monitoring the use and effectiveness of procurement processes;
• dealing with any queries; and
• auditing internal control systems and procedures.

Management
Management at all levels of CPC are responsible for ensuring those reporting to them understand and comply with this policy and that they are given adequate time to attend training regarding the issue of modern slavery in supply chains as appropriate.

Colleagues
The prevention, detection and reporting of modern slavery in any part of CPC’s business or supply chain is the responsibility of everyone working for or under the control of CPC.

5. Reporting Process

Raise your concerns

If modern slavery is suspected either within CPC’s own business or as part of the supply chain, take one or more of the following actions:

• If you believe someone is in immediate danger, call the emergency services.
• avoid any further activity that might lead to, or suggest, a breach of this policy;
• raise the concern with your Director at the earliest opportunity (or, if appropriate, directly with the Procurement Team); and
• notify the Procurement Team as soon as possible if you believe or suspect that a breach of this policy has occurred, or may occur in the future (you may also seek support from the HR Team).

If you are unsure about what constitutes the various forms of modern slavery, please contact the Procurement Team.

CPC will assess concerns promptly, take appropriate steps to investigate, and escalate to SLT and/or relevant authorities where required. Where concerns relate to a supplier, CPC may require corrective action, suspend work, or terminate the relationship depending on the circumstances.

Feel safe to raise your concern

CPC is committed to ensuring no one suffers any detrimental treatment as a result of reporting their suspicion that modern slavery is, or may be, taking place in any part of the business or its supply chain.

If you do not feel comfortable raising your concern internally, you can raise it with our independent whistleblowing service, SeeHearSpeakUp. Refer to the Whistleblowing Policy for more information.

Zero-tolerance

CPC may terminate its relationship with individuals, suppliers, and organisations if they are deemed to have breached this policy.

6. Communication and Awareness

CPC’s zero-tolerance approach to modern slavery will be adequately communicated to all agents, contractors, suppliers, consultants, third-party representatives, and other business partners and reinforced as appropriate thereafter.

7. Related documents

• Whistleblowing Policy
• Disciplinary Policy
• Grievance Policy
• Procurement Policy