Modern Slavery
Anti- Modern Slavery and Human Trafficking Policy
Introduction
The Company has a zero-tolerance approach to modern slavery and is committed to acting ethically, with integrity and transparency in all of its business dealings and relationships.
The Company is committed to implementing and enforcing effective systems and controls, to ensure that modern slavery and human trafficking are not taking place anywhere within either, its own business or in any of its supply chains. The Company endeavours to be consistent with its obligations under the Modern Slavery Act 2015.
The Company also expects the same high standards from all of its suppliers, contractors and other business partners and, as part of its contracting processes, it includes specific prohibitions against the use of modern slavery and expects that its suppliers will in turn hold their own suppliers to the same standards.
This policy applies to all individuals working for the Company or on the Company’s behalf in any capacity, including employees, directors, officers, agency workers, volunteers, agents, contractors, consultants and business partners.
Scope
Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many different ways.
Some suppliers may go to great lengths to hide the fact that they are using slave labour. However, the Company accepts that it has a responsibility through its due diligence processes to ensure that workers are not being exploited, that they are safe and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.
Responsibilities
The board of directors has overall responsibility for ensuring that this policy complies with the Company’s legal and ethical obligations. Alan Stuart has day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery.
They are also responsible for investigating allegations of modern slavery in the Company’s business or supply chains.
Line managers are responsible for ensuring that those reporting to them understand and comply with this policy.
Compliance responsibilities
The prevention, detection and reporting of modern slavery in any part of the Company’s business or supply chains, whether in the UK or abroad, is the responsibility of all those working for the Company or under the Company’s control. You are required to avoid any activity that might lead to a breach of this policy.
If you believe or suspect a breach of or conflict with this policy has occurred or may occur, you must notify your line manager or report it in accordance with the Company’s whistleblowing policy.
You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of the Company’s business or supply chains as soon as possible. If you are unsure about whether a particular act, the treatment of workers or their working conditions within any of the Company’s supply chains constitutes any of the various forms of modern slavery, please raise it with your line manager. You can also contact the government’s Modern Slavery Helpline on 0800 0121 700 for further information and guidance on modern slavery.
The Company aims 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.
The Company is committed to ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of its business or in any of its supply chains.
Protective measures
The Company is committed to
- Paying people fairly and properly for their work
- Transparent and fair behaviour, such as protecting human rights
- Compliance with legislation, including fundamental rights at work including elimination of discrimination throughout employment.
- Ensuring all work carried out by staff and those associated with the company is voluntary, and not done under any threat of penalties
The prevention, detection and reporting of modern slavery is the responsibility of all those working for the company or associated with the company. Staff and those associated with the company are required to avoid any activity that might lead to a breach of this policy.
Staff and associated individuals are expected to report concerns, using the appropriate reporting channels, and management are expected to act upon them.
Staff responsible for procurement or managing suppliers must follow due diligence including assessments and audits of product, services or geographical risks of modern slavery and human trafficking.
Breach of this policy
Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.
The Company may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery.
Communication
The company’s zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of its business relationship with them and reinforced as appropriate thereafter.
For any information regarding this policy please contact Justin Brinklow.