Modern slavery is a crime and a violation of fundamental human rights. It takes various, forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

We are committed to improving our practices to combat slavery and human trafficking. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Tufuta UK&I slavery and human trafficking statement for the financial year ending 2022.

A) ORGANISATION

This statement applies to Tufuta UK&I The information included in the statement refers to the financial year 2022.

B) ORGANISATIONAL STRUCTURE:

Tufuta UK&I, part of the Tufuta Group, are one of the UK and Irelands leading footfall analytics providers

Operating from Lidlington Bedfordshire and London:

C) DEFINITIONS

Tufuta UK&I considers that modern slavery encompasses the following; this list is not exhaustive.

• Human trafficking;
• Forced work, through mental or physical threat;
• Being owned or controlled by an employer through mental or physical abuse of the

threat of abuse;

• Being dehumanized, treated as a commodity or being bought or sold as property;
• Being physically constrained or to have restriction placed on freedom of movement.

D) COMMITMENT

Tufuta UK&I acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015.

We look to review this statement on an annual basis. Tufuta UK&I does not enter into business with any other organization, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour. No labour provided to Tufuta UK&I in the undertaking of the provision of its own services is obtained by means of slavery or human trafficking. Tufuta UK&I strictly adheres to the minimum standards required in relation to its responsibilities under the relevant employment legislation.

E) SUPPLY CHAINS:

We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors to comply with our values.

F) POTENTIAL EXPOSURE

Tufuta UK&I considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

G) DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING: Tufuta UK&I has not, to its knowledge, conducted any business with another organization which has been found to have involved itself with modern slavery. In accordance with section 54(4) of the Modern Slavery Act 2015, Tufuta UK&I has taken the following steps to ensure that modern slavery is not taking place:

• Member of globally recognised platform SEDEX (Supplier Ethical Data Exchange) of which we are group B members. Membership to SEDEX provides the Company with a platform to share information with our customers and assess our business practices
• We carry out robust due diligence pre - employment checks including references, eligibility to work in the United Kingdom and Republic of Ireland and proof of identification

• Systems in place to encourage the reporting of concerns and the protection of whistle blowers via a confidential reporting system.

H) MEASURES:

We use the following measures to check how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

• Right to work checks completed at recruitment stage;
• Ensure minimum employment age adhered to, in line with the relevant legislation;
• Always apply national minimum wage thresholds, in line with the relevant legislation;
• Employee monitoring (UK & Northern Ireland)

I) SLAVERY COMPLIANCE

The Company have trained personnel, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Company obligations in this regard. This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.