Anti-slavery policy
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 for their own personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically with integrity in all our business dealings and relationships. To ensure that modern slavery is not taking place anywhere in our own business or in any of our supply chains we will implement effective systems and controls.
Anti-slavery standards
We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all our contractors, suppliers and other business partners, and as part of our contracting processes we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude.
About this policy
The purpose of this policy is to:
- set out our responsibilities, and of those working for and on our behalf, in observing and upholding our position on modern slavery and human trafficking; and
- Provide information to those working for and on our behalf on how to identify and report concerns regarding modern slavery and human trafficking.
Applicable persons
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.
Employee policy
This policy does not form part of any employee’s contract of employment, and we may amend it at any time.
Responsibility for the policy
Overall responsibility
The board of directors or individual has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under their control comply with it.
Compliance manager
The HR Manager and/or Managing Director is responsible for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Training and compliance
Management at all levels are responsible for ensuring that those reporting to them understand and comply with this policy and receive adequate and regular training on the issue of modern slavery in supply chains.
Feedback encouraged
All employees are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions, and queries are encouraged and should be addressed to the Managing Director OR HR Manager.
Your responsibilities and how to raise a concern
Comply with policy
You must ensure that you read, understand, and comply with this policy.
Anti-slavery policy
It is the responsibility of all those working for us or under our control to avoid any activity that might lead to, or suggest, a breach of this policy. You are required to report any suspected breaches of this policy.
Breach of policy
You must notify your direct line manager OR the compliance manager as soon as possible if you believe or suspect that a breach of this policy has occurred or may occur in the future.
Modern slavery
You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business or supply chains, at the earliest possible stage.
Notify breach
If you believe or suspect that a breach of this policy has occurred or that it may occur, you must notify your direct line manager, the HR Manager and/or Managing Director OR report it in accordance with our Whistleblowing Policy as soon as possible.
Raise concerns
If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any form of modern slavery, raise it with your direct line manager or the HR Manager and/or Managing Director.
Protected reporting
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of raising a concern. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally in writing with our Managing Director.
Training and communication
Employee training
Training on this policy, and the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
Communication of commitment
Our zero-tolerance approach to OR Our commitment to addressing the issue of modern slavery in our business and supply chains must be communicated at the outset of our business relationship with them, and reinforced as appropriate on an ongoing basis.
Breaches of this policy
Disciplinary action
Any employee who breaches this policy will face disciplinary action, which may result in dismissal for misconduct or gross misconduct.
Termination
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.