Modern Slavery and Child Labour Policy

J and M Nixon Printers Ltd
Revised: November 2025

1. Policy Statement

J and M Nixon Printers Ltd is committed to conducting business in a lawful, ethical and responsible manner. We recognise that modern slavery, human trafficking and child labour are serious violations of human rights and have no place in our business or supply chains. This policy sets out our approach to preventing modern slavery, human trafficking and child labour within our operations and throughout our third‑party relationships.

This policy should be read alongside our Code of Ethics, Third Party Code of Conduct, Concerns at Work Policy and Procurement Procedures.

2. Scope

This policy applies to:

All employees, directors and officers of J and M Nixon Printers Ltd
All third parties acting on our behalf, including suppliers, contractors, agents and service providers
All supply chain activities connected to our business

3. Modern Slavery and Human Trafficking

3.1 Third Party Code of Conduct

Our Third Party Code of Conduct strictly prohibits the use of modern slavery and human trafficking. It also reconfirms our Code of Ethics requirement that relevant third parties must hold themselves, and their own suppliers, to the same high standards.

All third parties are expected to:

Comply with all applicable international, national and local labour laws
Ensure that forced, bonded or trafficked labour is not used in any part of their operations or supply chains
Take reasonable steps to identify and mitigate modern slavery risks within their own supply chains

3.2 Concerns at Work (Whistleblowing)

Our Concerns at Work Policy confirms our commitment to ensuring that employees and others can raise serious concerns regarding any aspect of their work, the conduct of others or the running of our organisation.

This includes, in particular, concerns relating to:

Modern slavery
Human trafficking
Forced or compulsory labour

Reports may be made in confidence and without fear of retaliation.

3.3 Procurement Procedures

Our Procurement Procedures are designed to work collaboratively with supply partners and their extended supply chains to minimise negative impacts arising from trading activities on:

Human rights
The environment
Local communities

We seek to embed ethical labour standards into procurement decisions and ongoing supplier management.

4. Our Supply Chain

Our product supply chains are restricted to UK suppliers and include:

Procurement of goods and services related to the production of printed materials
Procurement of goods and services not related to the production of printed materials
Production of items ancillary to the production of printed materials
Production of digital materials and platforms
Production of printed materials
Warehousing

5. Assessment of Modern Slavery Risk

Following a review of the principal activities within our supply chain, we have identified four main third‑party activities that could pose a potential risk from a modern slavery and human trafficking perspective:

Distribution
Production of items ancillary to the production of printed materials
Production of printed materials
Supply of electronic devices to the Press

These areas are subject to enhanced scrutiny as part of our due diligence processes.

6. Due Diligence Processes

We are committed to carrying out proportionate and risk‑based due diligence to understand whether there is evidence of modern slavery or human trafficking and whether appropriate controls are in place to prevent it.

All new third‑party relationships, and existing third parties undergoing review, are subject to our third‑party due diligence process, which includes:

Questioning around compliance with international labour laws, including specific questions on modern slavery and trafficked labour
Assessment of the processes third parties have in place to prevent modern slavery and human trafficking within their own operations and supply chains
Contractual terms that include anti‑modern slavery provisions

7. Measuring Effectiveness

We are committed to reviewing this policy annually, and more frequently if required by changes in circumstances or legislation.

To measure compliance and effectiveness, we monitor the following key performance indicators (KPIs):

Number of employees signed up to, or re‑signed to, the Code of Ethics
Number of third‑party risk assessments carried out
Number of due diligence processes completed
Number of audit processes completed

8. Child Labour Policy

8.1 Our Position

Our child labour policy sets out our position on employing minors and aims to ensure that our organisation, and everyone we are connected with, complies with the law and acts in the best interests of children.

While child labour laws are stricter today than in the past, millions of children worldwide are still forced to work in unacceptable conditions, including in developed countries. As an organisation, we are committed to doing business in a legal and ethical manner that adds value to society and the environment.

Preventing child labour and children’s exploitation is fundamental to our values.

8.2 Actions and Implementation

To enforce this policy and help eliminate child labour, we are committed to:

Working with other organisations and stakeholders to help end child labour
Educating our staff on youth employment laws and how to report suspected child labour
Requiring hiring managers to avoid employing minors below the legal working age
Ensuring hiring managers understand and comply with laws relating to wages, hours and working conditions for young workers of legal age
Maintaining and validating documentation that verifies employees’ age after hiring

9. Children’s Welfare

Children’s welfare is everyone’s responsibility. While we aim to grow and succeed as a business, we are equally committed to contributing positively to the communities in which we operate.

We expect all employees and partners to follow this policy, not only because it is required, but because safeguarding children and securing a positive future for them is a shared duty.

10. Responsibility and Compliance

Failure to comply with this policy may result in disciplinary action for employees and may lead to termination of contracts with third parties.

This policy is approved by senior management and reflects our ongoing commitment to ethical business practices.

J and M Nixon Printers Ltd