MODERN SLAVERY ACT 2015


TOWER TRANSIT’S POLICY ON THE PREVENTION OF SLAVERY AND HUMAN TRAFFICKING

Tower Transit is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain, and imposes the same high standards on its suppliers. It is important that Tower Transit is ethical in all dealings and has highest standards of business conduct with customers, suppliers, employees and the communities wherever they operate around the world.

In accordance with the Modern Slavery Act 2015, Tower Transit outline below its efforts to ensure the eradication of slavery, forced or compulsory labour, or human trafficking from our supply chains and business operations.

SUPPLIER STANDARDS

Tower Transit desires that each and every one of its suppliers conduct business in a lawful and ethical manner, including business practices that prevent slavery and human trafficking in its own supply chain. Tower Transit selects it suppliers and business partners carefully. Should any selected supplier not attain the standards that Tower Transit expects we will not do business with them.

HOW WE ARE ASSESSING AND MANAGING RISK

While most of Tower Transit’s supply chain is considered low-risk for modern slavery, we continuously evaluate potential risks. We aim to work exclusively with suppliers who share our commitment to eradicating slavery and human trafficking.

Tower Transit will always seek to reserve the right for itself or through third party auditors, to conduct, or have conducted on its behalf, audits of business practices to check suppliers’ commitments. Suppliers that fail to meet Tower Transit’s standards will be removed from Tower Transit’s supply chain.

TRAINING AND ACCOUNTABILITY

Tower Transit shall post this policy in all its locations in order to inform its management and employees of the issues on slavery and human trafficking so they can mitigate any risk and ensure that in the unlikely event that any is discovered in our supply chain that it is reported without delay.

KELSIAN GROUP’S GLOBAL COMMITMENT

Tower Transit is part of the Kelsian Group Limited, a publicly listed company in Australia. Kelsian Group is committed to upholding human rights across all operations worldwide, as detailed in its Human Rights Statement of Intent, which applies to all subsidiaries, including those providing public transport services in the UK, Channel Islands, and Singapore.

The Modern Slavery Act 2015 applies to UK-based businesses with an annual turnover exceeding £36 million. This statement is made on behalf of Kelsian UK Ltd and its subsidiaries, including Tower Transit Operations Ltd. Where required by law, copies of this statement will be provided upon request.

For more information on Kelsian Group’s Human Rights Statement of Intent, visit: Human Rights Statement of Intent

FURTHER ACTIONS AND SIGN-OFF

Following a review of our actions this financial year, we remain committed to taking further steps to prevent slavery and human trafficking within our operations and supply chains.

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Tower Transit’s slavery and human trafficking statement for the financial year starting 1st November 2024 and ending 31st October 2025.

Tower Transit reserves the right to amend this statement at any time without prior notice.