Modern Slavery Policy
Aim and Purpose of this Policy Statement
This statement aims to ensure 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 of 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, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
This statement 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.
This statement does not form part of any employee’s contract of employment and we may amend it at any time.
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 in order to exploit them for personal or commercial gain.
We have a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to
ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
The Directors have overall responsibility for ensuring this Policy statement complies with our legal and ethical obligations, and that is complied with it.
The Human Resource Departments has primary and day-to-day responsibility of implementation, 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.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this statement and are given adequate and regular training on it and the issue of modern slavery in supply chains.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead
to, or suggest, a breach of this Policy.
You must notify the Human Resource Department soon as possible if you believe or suspect that a conflict with this Policy has occurred or may occur in the future.
You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
If you believe or suspect a breach of Policy has occurred or that it may occur, you must report it to the nominated individual as soon as possible. You should note that where appropriate, and with the welfare and safety of local
workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains.
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 of the various forms of modern slavery, raise it with your
line manager or the Human Resource department.
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 reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.
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 Human Resource
department immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the Disciplinary and Grievance Policy.
Communication and Awareness
Training on this Policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work with us, and regular training will be provided as necessary.
Our zero-tolerance approach to modern slavery must be communication to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Policy Monitoring and Review
This Policy statement will be monitored periodically by the organisation to judge its effectiveness and will be updated in accordance with changes in the law.
Breaches of this Policy
Any employee who breaches its policy may face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with our other individuals or organisations working on our behalf if they breach this policy.