Modern Slavery Statement

NineAxis Limited is committed to conducting business responsibly, ethically and with integrity in every aspect of its operations. We recognise that modern slavery and human trafficking are serious criminal offences and gross violations of fundamental human rights. We are committed to preventing all forms of modern slavery within our own business, our workforce, our supply chain and every organisation with which we conduct business.

We believe that every individual has the right to work freely, safely and with dignity. We therefore operate a zero-tolerance approach towards slavery, servitude, forced or compulsory labour, debt bondage, child labour and human trafficking.

As a responsible facilities management provider, we understand that our reputation depends not only on the quality of our services but also on the ethical standards by which we operate. We are committed to ensuring that our business activities contribute positively to the communities we serve while promoting fairness, equality and respect for human rights.

Although NineAxis Limited is not currently required to publish an annual Modern Slavery Statement under Section 54 of the Modern Slavery Act 2015, we have voluntarily adopted this Statement as part of our wider commitment to good corporate governance, ethical procurement and responsible business practices.

This Statement reflects our values and demonstrates our commitment to continuous improvement as our business grows.

Purpose

The purpose of this Modern Slavery Statement is to outline the measures NineAxis Limited has implemented, and will continue to implement, to minimise the risk of modern slavery occurring within our business operations and supply chain.

The objectives of this Statement are to:

Promote ethical business conduct throughout the organisation.
Protect the rights, dignity and welfare of all workers.
Support lawful and responsible employment practices.
Establish clear expectations for suppliers and subcontractors.
Encourage transparency and accountability throughout our supply chain.
Strengthen governance arrangements that support responsible business practices.
Demonstrate our commitment to clients, employees, suppliers and stakeholders.

We recognise that preventing modern slavery is an ongoing responsibility requiring vigilance, collaboration and continuous improvement.

Legislative Framework

This Statement has been prepared with reference to:

- The Modern Slavery Act 2015

- The Human Rights Act 1998

- The Employment Rights Act 1996

- The Equality Act 2010

- The Health and Safety at Work etc. Act 1974

- Applicable UK employment legislation

- Internationally recognised principles relating to human rights and ethical labour practices, including the International Labour Organization (ILO) Core Conventions and the United Nations Guiding Principles on Business and Human Rights.

NineAxis Limited is committed to complying with all applicable legal and regulatory requirements governing employment, ethical business conduct and responsible procurement.

Scope

This Statement applies to every individual and organisation associated with NineAxis Limited, including but not limited to:

- Directors

- Employees

- Agency workers

- Temporary workers

- Contractors

- Consultants

- Apprentices

- Suppliers

- Service providers

- Subcontractors

- Business partners

- Recruitment agencies

- Any individual acting on behalf of NineAxis Limited

Every person representing NineAxis Limited is expected to uphold the principles contained within this Statement.

About NineAxis Limited

NineAxis Limited is a United Kingdom-based facilities support services company delivering integrated workplace, operational and environmental support services to organisations across both the public and private sectors. Our services are designed to create safe, compliant, efficient and professionally managed environments that enable our clients to focus on their core business activities. As our organisation expands, we recognise that our supply chain will continue to grow. We are therefore committed to developing relationships only with organisations that demonstrate ethical business practices and respect for human rights. We believe responsible procurement is fundamental to delivering sustainable and high-quality services.

Our Ethical Principles

The values of NineAxis Limited underpin every decision we make.

We are committed to:

- Acting honestly and ethically.

- Treating everyone with dignity and respect.

- Promoting equality, diversity and inclusion.

- Supporting safe and healthy workplaces.

- Protecting human rights.

- Operating transparently and responsibly.

- Encouraging accountability throughout our organisation.

- Building long-term relationships based on trust and integrity.

These principles influence how we recruit employees, engage suppliers, manage contracts and deliver services.

Our Commitment to Human Rights

NineAxis Limited respects internationally recognised human rights and is committed to ensuring that no individual connected with our business is subjected to exploitation or abuse.

We will not knowingly conduct business with any organisation involved in:

- Forced labour.

- Human trafficking.

- Child labour.

- Debt bondage.

- Servitude.

- Physical or psychological abuse.

- Exploitative working conditions.

- Unlawful discrimination.

Where concerns are identified, appropriate action will be taken to investigate and address those concerns.

Governance and Accountability

Overall responsibility for this Statement rests with the Directors of NineAxis Limited.

The Directors are responsible for ensuring that appropriate governance arrangements exist to support ethical business conduct throughout the organisation.

Management is responsible for:

- Promoting awareness of this Statement.

- Supporting ethical procurement practices.

- Encouraging responsible recruitment.

- Monitoring supplier relationships.

- Investigating concerns where appropriate.

- Reviewing compliance with this Statement.

Every employee also has a responsibility to uphold these standards and report concerns where necessary.

Risk Assessment

NineAxis Limited recognises that the risk of modern slavery exists across many industries and supply chains, including the facilities management sector. As our services develop and our supplier network expands, we acknowledge that certain activities may present a greater risk than others, particularly where subcontracted labour, temporary workers or outsourced specialist services are involved. To minimise these risks, we seek to identify and evaluate areas that may present increased exposure, including:

- Labour-intensive services.

- High-risk subcontracting arrangements.

- Temporary or agency labour.

- Cleaning and support service providers.

- Maintenance contractors.

- Overseas supply chains where applicable.

- Recruitment agencies.

- Suppliers operating in sectors or geographical regions recognised as carrying higher risks.

Risk assessments are reviewed periodically and incorporated into our wider supplier management and procurement processes.

Due Diligence

NineAxis Limited is committed to carrying out proportionate due diligence before entering into commercial relationships with suppliers, subcontractors and service providers.

Our due diligence approach may include:

- Assessing the reputation and credibility of prospective suppliers.

- Reviewing publicly available compliance information where appropriate.

- Confirming relevant business registrations and legal status.

- Considering previous performance and professional references.

- Reviewing policies relating to employment, health and safety, equality and ethical business practices where available.

- Assessing the suitability of suppliers based on the nature and risk profile of the services being provided.

Due diligence is intended to reduce risk while supporting long-term relationships with organisations that demonstrate responsible business practices.

Supplier and Subcontractor Standards

NineAxis Limited expects every supplier, subcontractor and business partner to operate responsibly and in accordance with applicable legislation.

Organisations working with NineAxis are expected to:

- Comply with the Modern Slavery Act 2015 and all relevant employment legislation.

- Ensure employment is freely chosen.

- Never engage in forced, compulsory or bonded labour.

- Prohibit child labour.

- Provide lawful wages and employment conditions.

- Respect freedom of association where applicable.

- Maintain safe and healthy workplaces.

- Prevent discrimination, harassment and abuse.

- Maintain accurate employment records.

- Cooperate with reasonable compliance requests made by NineAxis.

Where appropriate, suppliers may be requested to confirm their commitment to these principles during procurement or contract management activities.Failure to demonstrate acceptable ethical standards may result in corrective action, suspension or termination of the business relationship.

Ethical Procurement

NineAxis Limited believes responsible procurement is essential to maintaining ethical and sustainable business operations.

When selecting suppliers, procurement decisions may take account of factors including:

- Professional competence.

- Regulatory compliance.

- Quality management.

- Health and safety performance.

- Environmental responsibility.

- Ethical labour practices.

- Business integrity.

- Financial stability.

- Commitment to continuous improvement.

Commercial considerations will never justify knowingly engaging organisations involved in unethical employment practices.

Recruitment and Employment Practices

NineAxis Limited is committed to ensuring that all recruitment activities are conducted fairly, transparently and lawfully.

We aim to ensure that:

- Employment is entered into voluntarily.

- Every worker understands the terms of their employment.

- Employment contracts are clear and transparent.

- Recruitment practices comply with applicable legislation.

- Right-to-work requirements are verified where required by law.

- Recruitment fees are never charged to workers by or on behalf of NineAxis.

- Employees receive fair treatment regardless of age, disability, gender, race, religion, sexual orientation or other protected characteristics.

We encourage a workplace culture founded on dignity, inclusion and mutual respect.

Employee Awareness and Training

NineAxis recognises that awareness is an important element of preventing modern slavery.

As the Company grows, we will continue to promote awareness by:

- Communicating this Statement to relevant employees.

- Providing guidance on recognising indicators of modern slavery.

- Encouraging ethical decision-making.

- Promoting responsible procurement practices.

- Supporting managers in identifying and responding to concerns.

Training arrangements will continue to evolve in line with organisational growth and operational requirements.

Reporting Concerns

NineAxis Limited encourages employees, contractors, suppliers, clients and other stakeholders to report any concerns relating to suspected modern slavery, human trafficking or unethical employment practices.

Examples of concerns may include:

- Individuals appearing to be working under coercion.

- Unlawful deductions from wages.

- Restricted freedom of movement.

- Unsafe or degrading living conditions.

- Threats, intimidation or abuse.

- Suspicious recruitment practices.

- Evidence of child labour.

Reports may be made through appropriate management channels or directly to the Directors.

All concerns will be treated seriously and investigated appropriately.Individuals raising concerns in good faith will not suffer retaliation, victimisation or any form of detrimental treatment.

Investigation and Corrective Action

Where a concern relating to modern slavery is identified, NineAxis Limited will take appropriate and proportionate action based on the nature of the concern and the available evidence.

This may include:

- Conducting an internal review or investigation.

- Requesting additional information from the relevant supplier or contractor.

- Implementing corrective action plans where appropriate.

- Suspending procurement or contractual activities while concerns are investigated.

- Reporting suspected criminal activity to the appropriate authorities where required by law.

- Terminating business relationships where serious or persistent breaches are identified.

Our objective is not only to address individual incidents but also to strengthen our systems and reduce the likelihood of similar risks arising in the future.

Monitoring and Continuous Improvement

NineAxis Limited recognises that effective prevention of modern slavery requires ongoing monitoring and continual improvement.

We are committed to regularly reviewing our policies, procedures and governance arrangements to ensure they remain appropriate, proportionate and aligned with current legislation and recognised best practice.

As the Company develops, we will continue to strengthen our approach by:

- Periodically reviewing supplier due diligence processes.

- Assessing emerging risks within our operations and supply chain.

- Reviewing procurement procedures and contractual requirements.

- Monitoring compliance with internal policies.

- Encouraging feedback from employees, suppliers and stakeholders.

- Updating guidance and training where appropriate.

- Reviewing this Statement annually.

Continuous improvement forms an integral part of our commitment to responsible corporate governance.

Commitment to Clients and Stakeholders

Our clients place significant trust in NineAxis Limited to deliver services professionally, responsibly and ethically. We recognise that responsible business practices contribute to long-term partnerships, sustainable growth and public confidence.

Through this Statement, we reaffirm our commitment to:

- Conducting business with integrity.

- Respecting internationally recognised human rights.

- Supporting ethical employment practices.

- Promoting transparency throughout our supply chain.

- Working collaboratively with clients, suppliers and partners to reduce the risk of modern slavery.

- Maintaining the highest standards of corporate responsibility.

We expect our business partners to share these principles and work alongside us in creating safe, fair and respectful working environments.

Review of this Statement

This Modern Slavery Statement will be reviewed annually or sooner where there are significant changes to legislation, organisational structure, operational activities or identified risks.

The Directors of NineAxis Limited remain responsible for ensuring that this Statement reflects the Company's values, legal obligations and commitment to continuous improvement.

Where appropriate, amendments will be approved and communicated throughout the organisation.

For further information regarding this Modern Slavery Statement or to report any concerns relating to modern slavery, human trafficking or unethical labour practices, please contact:

NineAxis Limited

66 Paul Street

London EC2A 4NA

United Kingdom

Email: hello@nineaxis.co.uk

Telephone:+44 (0)7881 190082

We are committed to handling all enquiries professionally, confidentially and in accordance with applicable legal and regulatory requirements.

Approval

This Modern Slavery Statement has been approved by the Directors of NineAxis Limited and reflects the Company's commitment to ethical business practices, responsible procurement and the protection of human rights throughout its operations and supply chain.

Every employee, contractor, supplier and business partner is expected to support the principles contained within this Statement and contribute to maintaining the highest standards of integrity and corporate responsibility.

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