Modern Slavery and Human Trafficking Policy

Company Number: SC898389

1. Our Commitment

UTILITY PRICE CHECK LTD is committed to conducting business responsibly, ethically and with respect for fundamental human rights.

We have a zero-tolerance approach to modern slavery, forced labour, servitude, human trafficking and exploitation in our own operations and expect the businesses and individuals with whom we work to uphold comparable standards.

We recognise that modern slavery can occur in businesses and supply chains of every size and in many different sectors. We therefore aim to take proportionate and practical steps to identify, reduce and address relevant risks.

This Policy reflects our commitment to the principles of the Modern Slavery Act 2015.

2. About UTILITY PRICE CHECK LTD

UTILITY PRICE CHECK LTD is a business utilities intermediary operating in Great Britain and providing services to business and non-domestic customers.

Our services may include comparison, procurement, switching, referral and contract support relating to:

• business electricity
• business gas
• business water
• broadband and telecommunications
• business mobile services
• business waste
• other business utility services

We may work with a range of:

• energy suppliers
• water retailers
• telecommunications providers
• mobile providers
• business waste providers
• aggregators
• channel partners
• sub-brokers
• introducers
• technology providers
• professional advisers
• other third-party service providers

Our business model is predominantly service-based. Nevertheless, we recognise that modern slavery risks can arise indirectly through suppliers, contractors, service providers and wider supply chains.

3. What We Mean by Modern Slavery

For the purposes of this Policy, modern slavery includes practices such as:

• slavery
• servitude
• forced or compulsory labour
• human trafficking
• debt bondage
• exploitation of workers
• coercive recruitment practices
• other situations in which an individual is forced to work or provide services through violence, threats, deception, abuse of vulnerability or other forms of coercion

We also consider exploitative child labour and serious abuses of workers’ rights to be inconsistent with our ethical standards.

4. Zero-Tolerance Approach

UTILITY PRICE CHECK LTD does not knowingly:

• use forced, compulsory or trafficked labour
• employ individuals through coercion
• retain workers’ identity documents or passports as a means of control
• require employees or workers to pay improper recruitment fees
• knowingly work with organisations involved in modern slavery
• tolerate violence, intimidation or threats against workers
• knowingly benefit from human trafficking or exploitation
• conceal suspected incidents of modern slavery

If credible evidence indicates that a business partner is involved in modern slavery or human trafficking, we will consider appropriate action, which may include investigation, requiring remedial measures, suspending work or ending the commercial relationship.

5. Our Employees and Workers

We are committed to ensuring that people working for or on behalf of UTILITY PRICE CHECK LTD are treated fairly and lawfully.

Where applicable, we seek to ensure that:

• employment is voluntary
• employees and workers are free to leave employment subject to lawful contractual requirements
• employment terms are communicated clearly
• workers receive remuneration in accordance with applicable law
• working arrangements comply with relevant employment requirements
• discrimination, harassment, intimidation and abuse are not tolerated
• identification documents are not withheld as a condition of employment
• recruitment practices are conducted responsibly

We expect any recruitment agency or contractor used by us to apply comparable standards.

6. Our Suppliers and Business Partners

We expect Suppliers and Partners working with UTILITY PRICE CHECK LTD to conduct their businesses ethically and in compliance with applicable laws relating to:

• slavery
• human trafficking
• forced labour
• employment
• worker protection
• human rights

Our expectations apply, where relevant, to:

• utility Suppliers
• service providers
• contractors
• subcontractors
• introducers
• brokers and sub-brokers
• technology providers
• telecommunications providers
• waste contractors
• other organisations supporting our business

7. Supplier Due Diligence

We apply a proportionate and risk-based approach when selecting and reviewing third parties.

Depending upon the nature of the relationship and the level of identified risk, our due diligence may include:

• confirming the identity and legal status of a business
• reviewing publicly available company information
• checking relevant policies or compliance statements
• reviewing contractual arrangements
• assessing the nature and location of services
• considering the use of subcontractors
• requesting additional information where concerns arise
• reviewing regulatory or reputational concerns
• seeking confirmation of compliance with applicable laws

The amount of due diligence undertaken will reflect the nature, size and risk of the commercial relationship.

8. Higher-Risk Relationships

We recognise that modern slavery risk is not necessarily the same across every Supplier, service or geographical area.

We may apply additional scrutiny where factors indicate an increased risk, including circumstances involving:

• significant use of temporary or migrant labour
• complex subcontracting arrangements
• labour-intensive services
• recruitment through multiple intermediaries
• operations in jurisdictions associated with increased labour exploitation risk
• unusually low-cost labour arrangements
• reports of poor employment practices
• credible allegations of human rights abuses

Where risks are identified, we may request additional information or assurances before entering into or continuing a commercial relationship.

9. Business Waste and Other Contracted Services

Some services connected with our wider business activities may involve more labour-intensive supply chains than our core intermediary activities.

Where appropriate, we expect providers operating in areas such as:

• waste collection
• recycling
• telecommunications installation
• infrastructure work
• equipment supply
• logistics
• cleaning
• maintenance
• other contracted services

to maintain appropriate employment and ethical standards.

10. Working with Utility Suppliers

Our role as a TPI often involves introducing or arranging contracts between business customers and established utility Suppliers.

Where we become aware of credible concerns regarding the labour practices or supply chain of a Supplier or Partner, we will consider the information proportionately and determine whether further investigation or action is appropriate.

We do not assume that the size or reputation of an organisation eliminates modern slavery risk.

11. Recruitment

Where we recruit employees, contractors or other personnel, we aim to use responsible recruitment practices.

We will not knowingly use a recruitment organisation that:

• charges workers unlawful recruitment fees
• withholds identity documents
• uses misleading employment terms
• facilitates forced labour
• exploits vulnerable workers
• is involved in trafficking or other serious labour abuses

Where an external recruitment agency is used, we may conduct appropriate checks before engaging that organisation.

12. Responsibility for This Policy

Responsibility for overseeing this Policy rests with the management of UTILITY PRICE CHECK LTD.

Management is responsible for:

• promoting awareness of this Policy
• considering modern slavery risks where relevant
• reviewing credible concerns
• taking appropriate action where problems are identified
• periodically reviewing the effectiveness of our approach

All employees, contractors and representatives are expected to act consistently with this Policy.

13. Reporting Concerns

Anyone working for, dealing with or providing services to UTILITY PRICE CHECK LTD is encouraged to report concerns relating to suspected:

• forced labour
• slavery
• exploitation
• human trafficking
• coercive working conditions
• unethical recruitment
• serious worker abuse

connected with our business or supply chain.

Concerns can be reported to:

office@utilitypricecheck.com

or by telephone:

01312100401

Reports should contain as much relevant information as reasonably possible.

14. No Retaliation for Raising Genuine Concerns

We do not tolerate retaliation against an employee, contractor or other person who raises a genuine concern in good faith regarding suspected modern slavery or human trafficking.

A person raising a concern does not need to prove that modern slavery has occurred.

We encourage concerns to be reported where there are reasonable grounds for suspicion so that the matter can be considered appropriately.

Knowingly making a deliberately false or malicious allegation may, however, be treated separately.

15. Responding to Suspected Modern Slavery

Where a credible concern is reported, we will consider what action is appropriate according to the circumstances.

This may include:

• recording the concern
• assessing the available information
• requesting further information
• speaking with the Supplier or Partner concerned where appropriate
• seeking professional advice
• requiring corrective or remedial action
• suspending a commercial relationship
• terminating a commercial relationship
• reporting the matter to an appropriate authority where required or appropriate

Our response will take account of the seriousness of the allegation, available evidence and the potential risk to affected individuals.

16. Remediation Before Termination

Where appropriate and where individuals are not placed at further risk, we may seek to work with a Supplier or Partner to address an identified problem rather than automatically terminating the relationship.

This may include requesting:

• a corrective action plan
• improved recruitment procedures
• enhanced worker protections
• additional supply-chain checks
• staff training
• increased monitoring
• evidence that the underlying issue has been resolved

However, serious, deliberate or repeated violations may result in immediate termination of the relationship where legally and commercially possible.

The safety and welfare of affected individuals will be an important consideration in determining the appropriate response.

17. Training and Awareness

We seek to maintain awareness of modern slavery risks appropriate to the size and nature of our business.

Where relevant to an individual’s responsibilities, training or guidance may cover:

• indicators of forced labour
• human trafficking warning signs
• responsible Supplier selection
• reporting procedures
• recruitment risks
• exploitation of vulnerable workers
• appropriate escalation of concerns

More detailed training may be provided where an employee’s role involves procurement, Supplier management or other areas with increased exposure to modern slavery risks.

18. Warning Signs

Possible indicators of exploitation may include situations where a worker:

• appears frightened, withdrawn or controlled by another person
• cannot freely communicate
• has had identification documents taken away
• appears unable to leave employment
• works excessive hours under coercion
• lives in unusually poor accommodation controlled by an employer
• has unexplained deductions from wages
• owes substantial recruitment-related debt
• receives substantially different working conditions from those promised
• is transported or accommodated under highly restrictive conditions
• shows other signs of coercion or exploitation

The presence of one indicator does not necessarily prove that modern slavery is occurring, but concerns should not simply be ignored.

19. Breaches of This Policy

A serious breach of this Policy by an employee may result in disciplinary action, subject to applicable employment procedures and law.

A breach by a contractor, Supplier, Partner or other third party may result in:

• investigation
• a request for corrective action
• suspension
• refusal to award further business
• termination of the commercial relationship
• referral to an appropriate authority

The response will depend on the nature and seriousness of the breach.

20. Measuring Our Effectiveness

As our business develops, we may review appropriate indicators for assessing our approach to modern slavery.

These may include:

• number of concerns reported
• number of Supplier issues investigated
• completion of relevant due diligence
• Supplier compliance confirmations
• corrective actions requested
• relevant training completed
• commercial relationships terminated or suspended because of ethical concerns

The measures used will be proportionate to our size, operations and risk profile.

21. Continuous Improvement

Preventing modern slavery requires ongoing awareness rather than a one-off compliance exercise.

We therefore aim to continually improve our approach as:

• our business grows
• our Supplier network changes
• new risks emerge
• legislation or government guidance changes
• our understanding of supply-chain risks develops

22. Our Expectations of Business Partners

We encourage organisations working with UTILITY PRICE CHECK LTD to:

• comply with applicable modern slavery legislation
• treat workers fairly
• maintain appropriate recruitment controls
• investigate suspected exploitation
• provide safe channels for workers to raise concerns
• apply proportionate due diligence to their own supply chains
• take reasonable action when modern slavery risks are identified

Where appropriate, these expectations may be incorporated into our Supplier or Partner onboarding arrangements.

23. Annual Review

This Policy will normally be reviewed at least annually and may be updated sooner where:

• our business activities materially change
• significant new risks are identified
• legislation changes
• relevant government guidance changes
• improvements to our procedures are identified

24. Voluntary Transparency

Where UTILITY PRICE CHECK LTD is not legally required to publish a statutory Modern Slavery Statement for a particular financial year, we may nevertheless publish this Policy voluntarily as evidence of our commitment to responsible and ethical business practices.

If the Company becomes subject to a statutory requirement to publish an annual Modern Slavery Statement, we will review our reporting arrangements and prepare the appropriate annual statement in accordance with the applicable legal requirements.

25. Approval

This Policy has been adopted on behalf of:

UTILITY PRICE CHECK LTD Company Number: SC898389 Effective date: 17 August 2026 Approved by: Director, UTILITY PRICE CHECK LTD

Contact

Questions or concerns regarding this Policy should be directed to:

UTILITY PRICE CHECK LTD Email: office@utilitypricecheck.com Telephone: 01312100401 Website: businessenergypricecheck.com