Modern Slavery & Human Trafficking Statement

Introduction 

The Modern Slavery Act 2015 (“the Act”) requires organisations to publish a slavery and human trafficking statement on an annual basis where they have a turnover of over £36 million, carry on business in the UK and are supplying goods or services.  

This statement is in respect of the financial year ended 31 December 2024 and describes our commitment and steps taken to identify, prevent and mitigate modern slavery in our business and supply chains. 

The statement applies to both Mezzo Labs Ltd and its relevant subsidiaries to which the Act applies.  

Organisational structure and supply chains  

Bray Leino Labs is a trading of Mezzo Labs Limited, an agency owned by The Mission Group plc, headquartered in London, England (“the Company”). 

Given the nature of our business, in which the main asset is the intellectual property generated by our own staff, we do not have an extensive supplier network. 

Our supply chains consist largely of software and hardware providers, printers, professional services, media suppliers, insurance and benefit providers, office facilities and maintenance service providers, recruitment agencies and other marketing service providers.   

Policies and training 

We support the aims of the Act and will never knowingly deal with any organisation which is connected to slavery or human trafficking. 

Our policies and procedures have been updated to specifically reference modern slavery and human trafficking and reflect our commitment to implementing and enforcing systems of controls that prevent instances of modern slavery or human trafficking happening anywhere either within our organisation or in our supply chains.  

In particular, our policies and procedures seek to:  

• Educate staff and help them identify risk factors to which they should be alert, including appropriate preventative or corrective action they should take  

• Encourage reporting of actual or suspected instances of modern slavery or human trafficking, especially with regards to engaging suppliers 

• Engage in recruitment and employment practices which cannot constitute exploitation  

• Identify and minimise risks of modern slavery in our supply chain 

• Comply with Modern Slavery Legislation. 

Due diligence processes and risk assessment   

We have assessed, and will continue to assess on a regular basis, our various lines of business, geographical areas of operation and supply chains in an effort to identify any areas of high risk.    

Given the nature of the services we provide and our high standard of employment practices, we consider that we are at low risk of exposure to slavery and human trafficking. 

We are not aware of any areas of our operations and supply chains likely to lead to a breach of the Act. If any areas or suppliers with higher risk are identified, we will mitigate the risk by performing a more detailed review of the potential risk, including:  

• Gathering further information on the risk identified 

• Examining contractual terms 

• Assessing what steps have been taken vetting the supplier, for example whether a site visit to the supplier’s premises has been undertaken or is necessary  

Review 

During the year we have not become aware of any instance of actual or suspected slavery or human trafficking affecting our business. 

We will periodically review the effectiveness of the steps we are taking. 

This statement was approved by the Board of Mezzo Labs Limited and signed on its behalf by: 

Adrian Kingwell 

Chief Executive Officer, Mezzo Labs Ltd 

2 September 2025 

Labour Standards And Human Rights Policy 

Introduction 

The landscape of employment is changing fast. There is a broad mix of full-time, part-time and ‘gig economy’ contracts in use across a number of industries today. Increasing automation and digitisation affect the demand for workers and types of employment. The disruption by the pandemic has also led to new perspectives on the world of work. In a sustainable society in future, people have access to health, participatory processes, education, and justice. There are many ways labour standards and human rights are part of the day-to-day at Bray Leino Labs. 

Purpose 

Mezzo Labs Limited (“the Company”) recognises that its colleagues are its principal asset and is committed to treating them with fairness, respect and integrity. Through this policy, the Company commits to the following principles-based outcomes:   

• A safe and healthy working environment. 

• Operating in compliance with all relevant laws in the countries in which it operates including the law of the sea, as applicable. 

• A workplace free of discrimination (however unintentional) with equal opportunity at all levels of the company on matters such as sex, gender, gender reassignment, pregnancy and maternity, marital status, race, colour, religious beliefs, ethnic or national origin, age, disability, sexual orientation, economic deprivation, social status or trade union membership. 

• Zero tolerance and zero occurrence of unacceptable treatment of colleagues, such as physical punishment, abuse of colleagues, slavery, or other forms of abuse including the exploitation of children.   

• Remuneration that at the very least is sufficient to cover colleagues’ basic needs and provide them with the opportunity to improve their skills and capabilities. 

• Accessible and timely information for colleagues on the progress of the business and its strategy, and of any major changes which might affect them as a group or individually. 

• Access to representations from colleagues through national or international works councils, recognised trade unions or other recognised groups where appropriate. 

• A set of clear grievance and appeal procedures in each business, which are justly applied and clearly communicated. 

In countries or territories where international opinion believes there to be a generally low labour standards or transgressions of human rights, then the Company would put in place appropriate additional management processes to ensure that the principles described in this document are accounted for and embodied in decisions and actions in such territories.  

Commitments 

We are committed to working responsibly and with integrity. This Labour Standards and Human Rights Policy complements our existing suite of policies. 

This Policy commits to delivering decisions and actions that uphold the right to freedom of association and collective bargaining. Our core values represent the foundation for colleagues’ rights whereby the Company expects colleagues in all operations to respect colleagues’ rights to join or not to join a legally recognised trade union, or any other body representing their collective interests, guided by, and compliant with local laws and the law of the sea, as applicable. 

This includes the right to enter into constructive dialogue and bargain in good faith with trade unions or representative bodies on employment conditions, labour management relations, and matters of mutual concern with due regard to extents of practicability, taking national laws into consideration. This includes the right to participate in activities of such bodies and/or to become an official of the union and allow colleagues reasonable time off in order to carry out official duties or to undergo relevant training in connection with trade union activities. This is in line with Article 11 of the UK Human Rights Act, the UN Guiding Principles on Business and Human Rights, and with ILO core conventions. 

This Policy commits to decisions and actions that lead to the reduction and elimination of excessive working hours. The Company expects all colleagues to respect colleagues’ right to reasonable a work-life balance in compliance with local law and the law of the sea, as applicable, on working hours and overtime. Where instances of excess are detected, we commit to understanding the root cause and providing an appropriate response and resolution. We encourage family-friendly practices, and we encourage flexible and remote working. 

This Policy commits to decisions and actions that lead to the provision of a living wage at a minimum wherever we operate. Pay must be (at the very least) sufficient to cover colleagues’ basic needs and provide them with the opportunity to improve their skills, capabilities, or additional economic prosperity. We operate remuneration and reward policies and practices to ensure colleagues are fairly rewarded for the work that they do, and we regularly monitor this through regular in year reporting, reviewing all colleagues pay annually. 

This Policy commits to decisions and actions that provide employee engagement mechanisms that allow employee representatives to engage with company management. Company policy on labour standards is communicated globally to colleagues via our website and via internal communications channels such as our intranet and workplace communication tools. The information is currently provided in English only. Amongst its other responsibilities, our Board states that it formally encourages innovation to meet the needs of our stakeholders, including colleagues. 

This Policy commits us to review affiliations and support of initiatives and frameworks on labour standards. Whilst no formal affiliations exist at the time of writing, we are involved in mental health initiatives such as Unmind (an app) and those promoting greater diversity in the workplace such as the Tech Talent Charter, Race at Work Charter, 30% Club (as referenced on page 10 of our 2021 Gender Pay Report) and the Menopause Friendly Accreditation Programme. We are also a Disability Confident employer.   

Risk Assessment   

The Board set the Company's risk appetites and Risk Policy. The effectiveness of the Company's risk management and internal control systems was reviewed during 2021. The Risk Committee was responsible for monitoring the Company's overall risk appetite, tolerance, strategy and risk assessment processes, effectiveness of the Company's risk management and the Company's capability to identify and manage new and emerging risks and deal with any material breaches of risk limits. Assessment regarding exposure to risk from negative impacts relating to labour standards is carried out for new, as well as existing operations or projects. Examples include labour-related risk factors relating to COVID-19, culture and capability, and an increased focus on talent management. Engagement is part of this risk identification process.  

Human Rights 

As part of our ongoing monitoring of our modern slavery risk, in 2023 we began the process of re-examining our existing suppliers to assess the potential for any residual modern slavery risk. All of our operations were identified as carrying a low risk of modern slavery.  

The risk assessment process also applies to new suppliers, and it remains our policy to require new suppliers to be risk-assessed.   

The Company supports the rights of all people as set out in The Universal Declaration of Human Rights (UDHR). We acknowledge the responsibility of businesses to respect human rights, by acting with due diligence to avoid infringing on the rights of others and to address any transgressions. 

We aim to inculcate the following Human Rights Principles into the behaviours of our colleagues as in line with our core values. To achieve this aim, we require our colleagues to respect the rights of, and deal fairly with, all other colleagues and parties with whom they work.   

• Anti-corruption: The Company will not permit any act by any Saga plc business or colleague that is considered to be corrupt, either under relevant law or by reference to good business practice. 

• Respecting the human rights of our colleagues: As stated above, the Company will treat all colleagues and other individuals with dignity and respect and will comply with relevant laws and regulations to ensure a discrimination-free environment for all. The Company has zero tolerance of intimidating, hostile or offensive conduct by its colleagues. 

• The Company will not make use of forced labour and will not employ colleagues that are below the legal minimum age regulations in the countries in which it operates. Furthermore, the Company upholds children's rights in line with the Children's Rights and Business Principles3 and commits to comply with all regulations in relation to the prevention of child labour. 

• Respecting the human rights of our business partners: The Company monitors suppliers that operate in countries that may not have standards consistent with the Company’s expectations. Any ‘red flag’ cases are formally assessed to review social, ethical and environmental practices, in line with the good practice such as compliance with the UDHR. Where a breach is found, an appropriate response is implemented, such as corrective actions, engagement, or even termination of supply contract. 

• Respecting the human rights in the countries where we operate: The Company will not tolerate any connection with human rights abuse through business relationships. In circumstances where the Company may be able to effectively influence respect for human rights, it will seek to do so. 

• Monitoring the effectiveness of our human rights approach: The Company requires its business leaders to be responsible for enforcing our human rights approach, including ensuring that all colleagues within their business areas are aware of their own responsibilities. See our Risk Policy, Equal Opportunities Policy and Speak Up Policy.  

Our Modern Slavery Statement provides further detail on risk, due diligence, policies, training and audit.  Additionally, our approach to labour standards and human rights is designed to support the communities in which we operate, including through the employment of those from underprivileged groups, or deprived backgrounds, with poor social status or no formal education or qualifications. Under-privileged groups are beneficiaries in our ESG programmes such as charitable giving, and we monitor and respond to the concerns of key groups who are affected by the Company’s activities. 

Further information 

Should you have any questions about the content of this Policy, and you are a colleague at Mezzo Labs, please speak to your line manager or the People team at The MISSION Group plc. 

This statement was approved by the Board of Mezzo Labs Limited and signed on its behalf by: 

Adrian Kingwell 

Chief Executive Officer, Mezzo Labs Ltd 

2 September 2025