Introduction
Modern slavery is a crime and a violation of fundamental human rights. It includes 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 are committed to acting ethically and with integrity and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or supply chain. We are also committed to ensuring transparency, including in our approach to tackling modern slavery throughout our supply chain. We expect the same high standards from all of our contractors, suppliers and other business partners. 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, and we expect that our suppliers will hold their own suppliers to the same high standards.
This policy applies to all persons working for us or on our behalf in any capacity. 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
Management at all levels has responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. They also have day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with queries, and auditing internal control systems and procedures to ensure effectiveness. Lastly, management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given any required training.
Compliance
The prevention, detection, and reporting of modern slavery in any part of our business or supply chain 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 your Manager as 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 of suspicion of modern slavery in any parts of our business or the supply chains of any supplier tier at the earliest possible stage. If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify a Director immediately or report it in accordance with our Whistleblowing Policy.
If you are unsure about whether a particular act, the treatment of workers, or their working conditions, within any tier of our supply chain would be considered modern slavery, raise it with a Director.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they are mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reports in good faith. If you believe that you have suffered any such treatment, you should inform a Director immediately.
Communication And Awareness
Training on this policy, and on the risk our business faces from modern slavery in its supply chain will be given where needed.
Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Policy Breaches
Any employee who breaches this policy may face disciplinary action, up to and including dismissal.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
