Modern Slavery Policy

1. Introduction and Commitment

XO Rental Ltd (“XO Rental”, “the Company”) is committed to preventing acts of modern slavery and human trafficking within its business operations and supply chains. We recognise our responsibility to take a robust and proportionate approach to identifying, assessing, and mitigating the risk of modern slavery, in line with the UK Modern Slavery Act 2015.

Modern slavery is a serious crime and a violation of fundamental human rights. XO Rental has a zero‑tolerance approach to modern slavery and is committed to acting ethically and with integrity in all business relationships.

Although our turnover is below the statutory threshold for mandatory compliance with section 54 of the Modern Slavery Act 2015, we have chosen to publish this statement voluntarily as part of our commitment to transparency and ethical business practice.

This policy and statement sets out the steps we take to ensure that modern slavery is not taking place within our business or supply chains, and reflects our ongoing commitment to continuous improvement.

2. About XO Rental

XO Rental is a UK‑based equipment rental company supplying professional camera, lighting, and related technical equipment to the film, television, broadcast, and content‑creation sectors. Our operations are primarily based in the United Kingdom, with clients operating both domestically and internationally.

Our workforce consists of UK‑based employees and a limited number of freelance contractors engaged directly by the Company. XO Rental does not operate as a labour- supply or recruitment business.

3. Our Operations and Supply Chains

XO Rental’s core activities relate to the rental, preparation, transport, and support of technical equipment. Our principal supply chains include:

  • Manufacturers and distributors of professional camera, lighting, power, and grip equipment
  • Suppliers of batteries, electronic components, and accessories
  • Logistics, courier, and transport providers
  • Facilities, cleaning, and maintenance services (where applicable)
  • Professional services suppliers

The majority of our direct suppliers are UK‑ or EU‑based businesses. We recognise, however, that some equipment and components used in our sector are manufactured outside the UK, including in regions where risks of labour exploitation may be higher.

4. Risk Assessment

XO Rental considers the risk of modern slavery within its direct operations to be low, given that:

  • All employees are engaged in the UK under formal employment contracts
  • Freelance contractors are engaged directly and paid in accordance with agreed terms
  • Employment practices comply with UK employment and wage legislation

The Company acknowledges that the potential risk of modern slavery is more likely to arise indirectly within parts of its supply chain, particularly in relation to:

  • Overseas manufacturing of electronic and technical equipment
  • Multi‑tier supply chains beyond first‑tier suppliers
  • Sub‑contracted logistics and transport services

XO Rental adopts a risk‑based and proportionate approach, focusing attention on areas where risk is more likely to arise rather than making blanket or absolute claims.

5. Due Diligence and Supplier Expectations

XO Rental seeks to work with suppliers who share our commitment to ethical business practices. Our approach to due diligence includes:

  • Assessing suppliers based on the nature of the goods or services provided and associated risk
  • Prioritising reputable suppliers with established compliance standards
  • Including contractual provisions allowing for termination where modern slavery or human trafficking is identified or reasonably suspected
  • Reserving the right to seek assurances or information from suppliers where appropriate

Where concerns are identified, XO Rental will take proportionate steps to address the issue, which may include engagement with the supplier, corrective action, or termination of the business relationship.

6. Policies and Governance

This policy is supported by XO Rental’s wider governance framework, including:

  • Code of Conduct
  • Whistleblowing Policy
  • Grievance Procedures
  • Ethical procurement principles

Responsibility for modern slavery risk sits with the Company’s senior leadership team, with oversight from the Board.

7. Training and Awareness

XO Rental recognises the importance of awareness in preventing modern slavery. Training is provided on a proportionate basis, with relevant senior staff made aware of modern slavery risks and indicators within the Company’s sector and supply chains.

8. Reporting Concerns

Employees, contractors, and third parties are encouraged to report any concerns relating to modern slavery or human trafficking connected with XO Rental’s business or supply chains. Reports may be made via established management channels or through the Company’s whistleblowing procedures. Concerns can be raised without fear of retaliation.

9. Review and Approval

This policy and statement is made pursuant to Section 54 of the Modern Slavery Act 2015. It is reviewed annually and updated as necessary to reflect changes in the Company’s operations or risk profile.

Approved by: Board of Directors, XO Rental Ltd
Date: 22.08.2025