Modern Slavery and Human Trafficking Policy

Policy Statement
Margaret Douglas Associates Limited (trading as MD Associates Ltd) is committed to preventing slavery and human trafficking in all its forms, both within our business operations and throughout our supply chain. We operate with integrity and expect the same from all our partners, suppliers, and contractors.

This policy reflects our commitment to acting ethically and with integrity in accordance with the Modern Slavery Act 2015 and demonstrates the steps we take to ensure slavery and human trafficking are not taking place in our business or supply chains.

Organisational Structure and Business
MD Associates Ltd is a UK-based consultancy specialising in HR, business transformation, and strategic advisory services. We operate primarily in the UK and Ireland, providing consulting services to organisations across multiple sectors including logistics, retail, manufacturing, public services, and professional services.

As a professional services consultancy with limited supply chains, our operations present a low risk of modern slavery. However, we recognise our responsibility to remain vigilant and take appropriate action.

Our Supply Chains
Our supply chains are relatively simple and UK-focused, typically including:

• IT service providers and software suppliers
• Professional services (legal, accounting, insurance)
• Office equipment and supplies
• Marketing and communications services
• Administrative support services through related entities
• Associate consultants and affiliates

Due Diligence and Risk Assessment
We conduct appropriate due diligence on our suppliers, associates, and business partners, including:

• Assessing suppliers and associates for modern slavery and human trafficking risks
• Reviewing supplier and associate policies and ethical standards
• Including anti-slavery clauses in supplier and associate contracts
• Monitoring compliance throughout the business relationship
• Ensuring all personnel are properly employed with lawful contracts

Policies and Procedures
Our commitment to preventing modern slavery is supported by the following practices:

• Recruitment: All recruitment is conducted ethically with proper employment contracts and in compliance with UK employment law. We do not use recruitment fees or practices that could exploit workers.

• Pay and Conditions: All personnel are paid at least the National Living Wage with transparent terms and conditions.

• Identity Verification: We maintain robust identity verification procedures in compliance with anti-money laundering regulations, which also help identify potential exploitation risks.

• Whistleblowing: We encourage anyone who suspects modern slavery or human trafficking to report concerns through our confidential reporting channels.

• Training: Key personnel receive training on modern slavery risks and how to identify potential indicators.

• Third-Party Oversight: We monitor the practices of our associates and affiliates to ensure compliance with ethical standards.

Effectiveness and KPIs
We measure the effectiveness of our approach through:

• Annual review of supplier and associate compliance
• Monitoring of any concerns or reports raised
• Regular review and update of this policy
• Ensuring 100% of relevant suppliers and associates have appropriate anti-slavery provisions in contracts
• Review of employment practices and contractor arrangements

Reporting Concerns
If you suspect modern slavery or human trafficking within our business or supply chain, please report it immediately to:

John Smith: john@mdassociates.co.uk
Nicola Curry: nicola@mdassociates.co.uk

All reports will be treated confidentially and investigated thoroughly. We do not tolerate retaliation against anyone who raises genuine concerns.

Approval and Review
This policy has been approved by the Directors of Margaret Douglas Associates Limited and will be reviewed annually.

Signed: John Smith
Date: 10 March 2026
Director, MD Associates Ltd