TACKLING MODERN SLAVERY AND HUMAN TRAFFICKING

ES BROADCAST’S POLICIES IN RELATION TO MODERN SLAVERY AND HUMAN TRAFFICKING

This statement is made pursuant to Section 54 of the United Kingdom (UK)
Modern Slavery Act 2015 (the “Act”) to identify actions that ES Broadcast
has taken during the financial year ending 30 June 2018 to combat the risk
of slavery and human trafficking occurring in our business or our supply
chain.

Although ES Broadcast is not legally required by the Modern Slavery Act to
publish a slavery and human trafficking statement, we strongly believe that
we have a moral and ethical obligation to ensure that corporate social
responsibility is an intrinsic part of the company’s ethos and brand identity.
As such, we have chosen to make transparent our commitment to
eradicating slavery and human trafficking in our supply chain.

Slavery and human trafficking can occur in many forms, including forced
labour, child labour, domestic servitude, sex trafficking, and related forms of
workplace abuse. In this statement, the terms “slavery and human
trafficking” are used to include all forms of slavery, servitude and forced or
compulsory labour, and human trafficking.

ES Broadcast is committed to maintaining and improving our business
processes and systems to help ensure that there are no human rights
violations related either to our own operations or our supply chains. Our
recruitment and employment policies/practices prohibit any form of forced,
involuntary or child labour in our operations, requires the company to adopt
sound labour and employment practices, and to treat all employees in
accordance with applicable laws at all times, including those governing
working hours, working conditions, fair remuneration and health and safety.

These policies also direct us to work with reputable suppliers for third-party
services, such as maintenance and cleaning of business premises. Our board
of directors is responsible for taking appropriate steps to ensure compliance
with employment law and with our own internal policies, and have
established disciplinary procedures, including termination of employment,
to deal with any violation of these laws or policies.

OUR STRUCTURE, BUSINESS AND SUPPLY
CHAINS

ES Broadcast supplies professional broadcast equipment and associated
services to the television, broadcast, audio-visual and cinema industries. The
company is an approved reseller for many leading broadcast manufacturers,
and also operates one of the largest second-hand equipment sales
operations in Europe.

As of January 2019, ES Broadcast employs approximately 32 staff across two
locations in the UK. We procure goods from manufacturers, distributors,
resellers and other suppliers located throughout the world. In some
instances, such as overseas projects, we may also contract with third parties
to provide skilled labour in order to provide specific services.

DUE DILIGENCE PROCESSES IN RELATION TO
MODERN SLAVERY AND HUMAN TRAFFICKING

ES Broadcast is committed to working with suppliers who share and adhere
to our principles of corporate social responsibility.

Many of our suppliers are large, multi-national manufacturers who are
themselves obliged by the Modern Slavery Act to address the threat of
slavery and human trafficking and to demonstrate transparency through
statements similar to this one. By striving to engage wherever possible in
authorised supply relationships of this nature, we can be confident that our
suppliers are committed to eradicating modern slavery in their supply chain.
And as an approved reseller for these manufacturers, ES Broadcast is itself
required to adhere to the business practices set out in any code of conduct
they may stipulate as part of our reseller agreement.

Where we deal with suppliers that are not major manufacturers and/or that
are not legally obliged to demonstrate compliance with the Modern Slavery
Act, we have undertaken a commitment, wherever possible, to work with
suppliers with whom we have a longstanding relationship and who we can
be confident share our commitment to tackling the threat of modern
slavery. We will always strive to favour companies that have undertaken
anti-slavery measures such as voluntarily publishing a slavery and human
trafficking statement, or producing a modern slavery and human trafficking
policy.

IDENTIFYING AND MANAGING RISK OF
MODERN SLAVERY AND HUMAN TRAFFICKING

We employ rigorous hiring procedures and have implemented robust
employment policies and other controls to mitigate the risk of slavery and
human trafficking in our own business operations.

Much of our supply chain is reliant on third-party manufacturers of the
equipment we sell. In identifying potential risks of slavery and human
trafficking in our supply chain, we are led by these manufacturers’ own
policies and internal risk assessments. We review these suppliers’ own
annual anti-slavery and human trafficking statements to help us understand
what areas they have deemed a particular risk. We seek to satisfy ourselves
that the actions they have taken to mitigate this are adequate.

Where our supply chain involves a company that is not subject to the
Modern Slavery Act, we acknowledge that the risk of slavery and/or human
trafficking may be greater, especially where there is a lack of transparency.
We can mitigate this risk by seeking to use suppliers who voluntarily publish
an anti-slavery and human trafficking statement, and by actively
encouraging suppliers who have not yet done so to take the step of
assessing their own anti-slavery policies.

We are also working towards developing a supply chain assessment and
audit procedure, to enable procurement staff to evaluate compliance in the
suppliers we use.

MEASURING THE EFFECTIVENESS OF ANTI-SLAVERY AND HUMAN TRAFFICKING PROCEDURES

We believe that measuring the effectiveness of our efforts is essential to
eradicating slavery and human trafficking. We propose doing this by
reviewing the following key performance indicators:

Staff training levels
Number of slavery incidents reported in our supply chains

RAISING AWARENESS AND TRAINING LEVELS
IN OUR STAFF

As part of our commitment to raising staff awareness about the issue of
modern slavery and human trafficking, staff are required to familiarise
themselves with and adhere to the company’s policies about modern
slavery, human trafficking, recruitment, staff working conditions, and supply
chains and procurement.

We plan to deliver online training modules to all staff on modern slavery.
We also aim to develop additional training materials and resources for
procurement and other relevant staff to help them identify risks of slavery
and/or human trafficking and reporting suspected instances of slavery or
trafficking.

We also propose reviewing our internal policies for effectiveness and
updating or implementing new policies where we deem it necessary.

This statement relates to the financial year ending 30 June 2018.