POLICY STATEMENT

Our policy applies to all our workers, our subcontractors, their subcontractors and their workers unless notified in writing that this isn’t the case. We use the term workers to cover all scenarios.

Long O Donnell recognises our responsibility to ensure sound social and ethical practices within our own operations and those within our supply chain. We believe that every worker has the right to live and work with dignity. We have a zero-tolerance approach to any form of modern slavery, and we are committed to creating effective systems and putting controls in place to safeguard against any form of modern slavery or human trafficking taking place within our business or our supply chain. LOD acknowledges the responsibility to the Modern Slavery Act 2015 and will ensure transparency within the company and also with our suppliers. We expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons:

a) Working for Long O Donnell, or on our behalf, in any capacity. Including employees at all levels, directors, agency workers, and volunteers.

b) Our contractors, external consultants, agencies, and third-party representatives.

Long O Donnell is committed to:

a) We will not support or deal with any business knowingly involved in Modern Slavery or Human Trafficking.

b) We will take appropriate steps to ensure everyone who works within our business has their fundamental human rights respected and anyone we do business with upholds these principles.

c) We will act ethically and with integrity in all our business dealings and relationships.

d) We will ensure there is transparency in our approach to tackling modern slavery and human trafficking in our business and in our supply chains consistent with our disclosure obligations under the Modern Slavery Act 2015.

The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.

Communication & awareness of this policy

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.

Breaches of this policy

If we find that individuals or organisations working on our behalf have breached this policy, we will ensure that appropriate action is taken to address this. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may also terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

The Chief Executive of Long O Donnell is responsible for the development and effective implementation of this Policy and for ensuring that the necessary resources are provided for its implementation through our processes.

Thomas J. O’Donnell

Chief Executive – Long O Donnell

January 2024