Modern Slavery & Human Trafficking Statement

1. Our Commitment

AVTAV Ltd operates a strict zero-tolerance policy towards modern slavery, forced labour, and human trafficking in all its forms. This is not merely a legal obligation — it is a fundamental part of how we conduct our business and a reflection of our values as an organisation.

We recognise that as a provider of recruitment, vetting, and training services within the aviation and security sectors, we operate in an environment where the risk of worker exploitation can exist. We take this responsibility seriously and have built robust systems, checks, and controls specifically designed to prevent, detect, and respond to any such risks across our entire operation and supply chain.

This statement is made on behalf of AVTAV Ltd and applies to

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2. About Our Business

AVTAV Ltd is a UK-based company registered in England and Wales (Company No: 12704296), headquartered at Suite A, Ground Floor, Sovereign Court, 625–635 Sipson Road, West Drayton, UB7 0JE.

We provide a specialist range of services including:

• Temporary and permanent labour supply to the aviation and security industries

• Accredited security industry training and certification

• Aviation cargo and compliance training, including CAA-approved programmes

• Comprehensive background screening, vetting, and identity verification services

The nature of our work — placing individuals into safety-critical, regulated environments — means that thorough due diligence is built into every step of our process. This rigour directly supports our commitment to eliminating modern slavery risks.

3. Our Policies & Governance

AVTAV Ltd maintains a suite of policies that together form a comprehensive framework for preventing modern slavery and related exploitation:

• Modern Slavery & Human Trafficking Policy — setting out our zero-tolerance position and responsibilities at every level of the business

• Recruitment & Safer Hiring Policy — ensuring all workers are engaged lawfully, transparently, and on fair terms

• Right to Work Policy — mandating verification of every individual’s legal entitlement to work in the UK before any engagement

• Supplier & Client Due Diligence Policy — establishing requirements for third parties we work with

• Whistleblowing Policy — providing a confidential mechanism for staff, workers, and third parties to raise concerns without fear of reprisal

• Anti-Bribery & Corruption Policy

• Code of Conduct — governing ethical standards for all employees, contractors, and partners

All policies are reviewed annually and communicated to relevant staff as part of induction and ongoing compliance activities.

4. Due Diligence & Checks

AVTAV Ltd operates one of the most thorough candidate screening and vetting processes in our sector. Every individual placed through our business — whether into a client site or into training — is subject to a rigorous, multi-stage due diligence process before, during, and after placement.

Pre-Placement Checks (carried out on every candidate without exception):

• Full identity verification — government-issued photographic ID verified against the individual in person or via certified digital means

• Right to Work verification — carried out in accordance with Home Office guidelines; no individual is placed without confirmed legal entitlement to work in the UK

• DBS (Disclosure and Barring Service) checks — at the appropriate level for the role, including enhanced checks where required by the client or regulatory environment

• Employment history verification and reference checks — references are actively followed up and validated; gaps in employment are investigated and documented

• CAA background screening — where applicable for aviation roles, candidates are subject to CAA-mandated background checks in line with aviation security regulations

• Address and residency verification

• Sanctions and watchlist screening where appropriate to the role

Supply Chain & Client Due Diligence:

AVTAV Ltd maintains a formal, documented supplier and client due diligence process. Before entering into any business relationship, we assess the other party’s compliance with relevant legal and ethical standards, including their approach to worker welfare and modern slavery. This includes:

• Requiring suppliers and labour sub-contractors to confirm compliance with the Modern Slavery Act 2015

• Assessing the working conditions and labour practices of client sites where our workers are placed

• Applying enhanced due diligence where a client or supplier operates in or adjacent to high-risk sectors — including food production, food processing, agriculture, cleaning, and hospitality — which are consistently identified by the GLAA and Home Office as sectors with the highest rates of labour exploitation and modern slavery in the UK

• Retaining the right to audit, inspect, or investigate any part of our supply chain where concerns are raised

• Terminating relationships with any party found to be non-compliant with our standards

Ongoing Monitoring:

Our due diligence does not end at the point of placement. We maintain active relationships with our placed workers and regularly check on their welfare and working conditions. Any concerns raised — by the worker, a client, or a third party — are investigated promptly and escalated where necessary.

5. Risk Assessment

We conduct regular risk assessments across our operations and supply chain to identify areas of potential exposure to modern slavery. Key risk factors we assess include:

• Sectors and roles with higher vulnerability to exploitation

• Nationalities or immigration statuses that may increase vulnerability

• Geographic origin of supply chain partners

• Labour market conditions and demand pressures that could incentivise non-compliance

We are acutely aware that certain industries carry a significantly elevated risk of modern slavery and forced labour. The food production, processing, and agricultural sectors are widely recognised — including by the Home Office and the Gangmasters and Labour Abuse Authority (GLAA) — as among the highest-risk environments for worker exploitation in the UK. Workers in these sectors are frequently targeted due to language barriers, precarious immigration status, isolation, and dependence on their employer for housing. Where any part of our supply chain or client base has connections to the food sector, we apply enhanced scrutiny and additional due diligence as standard.

Based on our assessments, we consider our direct risk to be low, owing to the rigour of our pre-placement screening and the highly regulated nature of the sectors we primarily operate in. However, we do not become complacent. We continue to evolve our risk assessment in line with Home Office guidance, GLAA intelligence, sector best practice, and our own operational activity.

6. Training & Awareness

All AVTAV Ltd staff receive modern slavery awareness training as part of their induction. This training covers:

• What modern slavery and human trafficking are, and the forms they can take

• Warning signs and indicators to look out for in candidates, workers, and supply chain partners

• How to report concerns internally and externally

• AVTAV’s legal and ethical obligations under the Modern Slavery Act 2015

Staff involved in recruitment, vetting, screening, and supplier management receive additional, role-specific training to ensure they are equipped to identify and respond to risks at the points of greatest exposure in our process.

Training is refreshed annually and whenever significant changes in legislation or best practice occur.

7. Reporting Concerns

AVTAV Ltd encourages anyone — employee, worker, client, supplier, or member of the public — who has concerns about modern slavery or human trafficking connected to our business to come forward. All reports are treated seriously, investigated thoroughly, and handled confidentially where possible.

Concerns can be raised:

• Internally — via any line manager or directly with our designated Compliance Lead

• Confidentially — via our whistleblowing process, which protects individuals from any detriment as a result of raising a concern in good faith

• Externally — via the Modern Slavery Helpline: 0800 0121 700 or www.modernslaveryhelpline.org

• To the police — if there is immediate risk to a person’s safety, always call 999

AVTAV Ltd will co-operate fully with any statutory authority, regulatory body, or law enforcement agency investigating concerns related to modern slavery.

8. Responsibility & Oversight

Overall responsibility for this statement and AVTAV Ltd’s compliance with the Modern Slavery Act 2015 rests with our senior leadership team. Day-to-day oversight is managed by our designated Compliance Lead, who is responsible for:

• Maintaining and reviewing this statement annually

• Overseeing training and awareness activities

• Managing due diligence processes and supplier assessments

• Investigating and escalating any concerns raised

• Keeping abreast of legislative and regulatory developments

9. Continuous Improvement

AVTAV Ltd is committed to continuously strengthening our approach to tackling modern slavery. We will continue to review and enhance our policies, processes, and training as our business grows and as best practice evolves. We will update this statement annually to reflect the steps taken during the preceding year and the priorities for the year ahead.

10. Approval & Sign-Off

This statement has been reviewed and approved by the board of directors of AVTAV Ltd for the financial year 2025–2026. It will be reviewed no later than April 2027.

Signed on behalf of AVTAV Ltd:Munyati

Director

AVTAV Ltd

Date: 01/04/2026

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