Modern Slavery and Human Trafficking Statement

For the Financial Year Ending 31st January 2026

1. Introduction & Governance

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015. Zenix Aerospace (“the Company”) maintains a zero-tolerance approach to modern slavery and is committed to ensuring transparency within our own business and throughout our global supply chains.

2. Our Business & Supply Chain Complexity

As a UK-based global aerospace leader, our supply chain is characterized by high-precision engineering and the sourcing of specialised raw materials.

  • Operations: 8 sites across the UK, Asian and the USA.
  • Workforce: Approximately 2,000 employees, primarily highly skilled engineering and manufacturing staff.
  • Supply Chain Tiers: Our supply chain is multi-tiered and global. We recognise that while our Tier-1 partners are often large, regulated OEMs, risks increase significantly at Tier-2 and beyond—specifically in the extraction of raw materials (e.g., Titanium, Cobalt, Lithium) and in lower-tier component machining.

3. Industry-Specific Risk Assessment

In this reporting period, we will develop our risk mapping to focus on three “high-alert” areas specific to aerospace:

  • Raw Material Sourcing: Identifying “conflict minerals” and metals sourced from regions with documented labour abuses.
  • Temporary & Contract Labour: Recognising that facilities management, logistics, and seasonal manufacturing surges often utilise agency workers who are at higher risk of exploitation.
  • Geographic Vulnerability: Mapping our Tier-2 suppliers against the Global Slavery Index to prioritize audits in high-risk territories.

4. Due Diligence & “Right to Audit”

We will implement an “active” due diligence model:

  • Supplier Onboarding: New suppliers to complete a mandatory Modern Slavery Self-Assessment Questionnaire (SAQ) before being granted preferred status.
  • Contractual Rigour: All new contracts to include “Right to Audit” and “Termination for Breach” clauses specifically linked to labour standard violations.
  • Verification: Spot-checks on “Right to Work” documentation for all on-site contractors and subcontractors to ensure no “debt bondage” or document withholding is occurring.

5. Training & Capacity Building

We believe awareness is the best preventative tool. During this financial year:

  • Targeted Training: 100% of our Procurement teams to complete training on identifying “Red Flags” in supplier behaviour.
  • Whistleblowing: Our “Speak Up” hotline is available 24 hours a day, 365 days a year. We have ensured this service is accessible in the primary languages of our global manufacturing hubs.

6. Measuring Effectiveness (KPIs)

To hold ourselves accountable, we track the following metrics:

  • Training Completion of our Procurement teams in identifying “Red Flags in Supplier behaviour
  • Whistleblowing Reports, numberTracked & Investigated versus 100% 
  • Code of Conduct Sign-off number signed off versus 100% of new suppliers

7. Future Actions & Remediation

We recognize that finding a “red flag” is a sign of an effective system, not a failure. If modern slavery is identified, we commit to a Victim-Centred Remediation approach, working with NGOs to ensure the safety of the individual rather than simply terminating a contract and leaving victims in further danger.

Signed: Scott McClarty Group Chief Executive Officer