Company: Quil Holdings Ltd
Company Registration Number: 021904V
Effective Date: 1st February 2026
Review Date: 1st February 2027

1. Policy Statement

Quil Holdings Ltd is committed to preventing modern slavery, forced labour, and human trafficking in all parts of its business and supply chains. We have a zero-tolerance approach to modern slavery and are committed to acting ethically, responsibly, and transparently.

This policy supports our obligations under the Modern Slavery Act 2015 and reflects our commitment to respecting human rights.

2. Scope

This policy applies to:

  • All employees, directors, and officers of the Company
  • Contractors, consultants, agency workers, and other third parties
  • Suppliers and business partners providing goods or services to the Company

3. Definitions

Modern slavery includes slavery, servitude, forced or compulsory labour, and human trafficking, as defined in the Modern Slavery Act2015.

4. Our Business and Supply Chains

Quil Holdings Ltd operates primarily within the United Kingdom. We recognise that modern slavery risks can exist in all industries and are committed to identifying and mitigating those risks within our operations and supply chains.

5. Responsibilities

Management

  • Promote a culture of ethical behaviour and compliance
  • Ensure appropriate systems and controls are in place to prevent modern slavery

Employees and Contractors

  • Act in accordance with this policy
  • Remain vigilant to potential indicators of modern slavery
  • Report any concerns or suspicions promptly

6. Risk Assessment and Due Diligence

To minimise the risk of modern slavery, the Company will:

  • Assess  modern slavery risks within its business and supply chains
  • Conduct due diligence on suppliers where appropriate
  • Consider modern slavery risks when onboarding new suppliers
  • Take appropriate action where risks are identified

7. Reporting Concerns

Any employee, contractor, or third party who has concerns about modern slavery or human trafficking related to the Company’s business must report them as soon as possible.

Reports can be made to Company management. Reports will be treated seriously, investigated appropriately, and handled confidentially where possible.

The Company will not tolerate retaliation against anyone who raises a concern in good faith.

8. Training and Awareness

The Company will:

  • Promote awareness of modern slavery risks
  • Provide guidance to employees where appropriate
  • Ensure relevant personnel understand their responsibilities under this policy

9. Breach of Policy

Any breach of this policy may result in disciplinary action, termination of contracts, or other appropriate action.

10. Review and Continuous Improvement

This policy will be reviewed annually and updated as necessary to reflect changes in legislation, business operations, or risk exposure.

11. Approval

This Modern Slavery and Human Trafficking Policy is approved by the management of Quil Holdings Ltd and is effective from the date shown above.