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Modern Slavery Act Transparency Statement

This slavery and human trafficking statement is made
pursuant to section 54(1) of the Modern Slavery Act 2015. It constitutes our
statement for the financial year ending 31 December 2022.

Introduction from the chief executive officer

A review of our slavery and human trafficking statement was undertaken during the course of the year. We remain committed to improving our practices to combat slavery and human trafficking.

We have a zero-tolerance approach to modern slavery across all areas of our organisation, as well as in our supply chains. We are committed to ensuring that we are not connected to modern slavery in any way. We aim to ensure that our business operates in an open and transparent way and our approach to tackling modern slavery throughout our supply chains is consistent with our obligations under the Modern Slavery Act 2015.

Neurön Consultancy has a firm set of organisational values that encompass everything we do. Our values were established through an organisation-wide staff consultation and a series of values workshops, which involved members of staff at all levels. We are justifiably proud of this bottom-up approach, an approach that has ensured our values reflect both our business and our staff. We positively promote these values in our activities and places of work.

Clients

We treat clients the way we would want to be treated

People

We care for our people through a supportive working environment

Excellence

We strive for excellence

Organisational structure

Neurön Consultancy is dedicated to advising clients in respect of the management and utilisation of their physical assets. We operate in many regions of the world and have offices in France, Netherlands, Morocco, New Zealand, French Polynesia and Greece.

As a professional services business our supply chain is relatively limited. Further information about our global services, industries and locations can be found at www.thevenotandpartners.com

Our policies on slavery and human trafficking

We aim to work in partnership with all our contractors, suppliers and other business partners to ensure that they share and work towards our opposition to slavery and human trafficking. To manage this, as part of our contracting processes, we include specific prohibitions on the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect our suppliers to hold their own suppliers to the same high standards. We check that new suppliers, where required, have published their own modern slavery statement.

Our anti-slavery policy is available to all our staff via the company intranet and we inform our suppliers of our commitment to preventing modern slavery through their service contract.

Due diligence processes regarding modern slavery and human trafficking

People – recruitment and employment

As a professional services organisation we deliver our services through our high-quality staff and as such we have robust recruitment practices supported by representatives of our People Team in each region in which we operate. Checks include evidence to support candidates’ ‘right to work’. This close involvement and oversight limits the risk of employing anyone who is forced or trafficked labour.

Where we have sub-consultants or contractors providing services on our behalf we require them to comply with our terms which include reference to the procedures and practices outlined in the Neurön Consultancy anti-slavery and human trafficking policy statement.

The prevention, detection and reporting of modern slavery in any part of our organisation or supply chains is the responsibility of all those working for us or under our control. Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy. Employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our organisation or supply chains at the earliest possible stage.

Whistleblowing arrangements

We encourage the reporting of any wrongdoing through internal and external whistleblowing procedures. These procedures also contain arrangements to ensure the protection of whistleblowers.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our organisation and our supply chains, we intend to roll out a training programme to our staff.

Suppliers

We have, and are improving, our arrangements to identify and manage potential risk areas in our supply chain and to work with them through requiring their compliance with the Modern Slavery Act and building long-standing relationships with them.

We are committed as an organisation to tackling modern slavery and human trafficking and want to work with suppliers who share our values. To ensure contractors and those in our supply chain comply with our values, we have in place a supply chain compliance programme which includes standard clauses in sub-contractor/sub-consultant contracts. In addition, we have a compliance team, which involves members of the legal, people and finance departments.

Further Steps

Following a review of the effectiveness of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains, we are committed to improving our practices to combat slavery and human trafficking. We have identified areas of improvement and instigated a set of actions to address these over the coming year. Updates will be provided in future statements.

We will carry out a review exercise annually to gauge the effectiveness of our arrangements.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and was approved by the Neurön Consultancy board of directors in April 2022.

Thomas Thevenot

Chairman

© 2022 Neurön SAS

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