Anti-Slavery and Human Trafficking Policy
1. Policy Statement
1.1 Modern slavery is a crime and a severe violation of fundamental human rights. It encompasses various forms, such as slavery, servitude, forced labor, and human trafficking, all of which involve the exploitation of individuals through the deprivation of their liberty. We maintain a zero-tolerance approach to modern slavery and are committed to ethical conduct and integrity in all our business operations and relationships. We implement and enforce effective systems and controls to ensure that modern slavery does not occur within our own business or our supply chains.
1.2 We are dedicated to transparency in our business practices and in our efforts to combat modern slavery within our supply chains, in line with our obligations under the Modern Slavery Act 2015. We expect our contractors, suppliers, and business partners to uphold the same high standards. Our contracting processes include explicit prohibitions against forced, compulsory, or trafficked labor, and we expect our suppliers to enforce these standards with their own suppliers.
1.3 This policy applies to all individuals working for or on behalf of our organization, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.
1.4 This policy is not part of any employee's contract of employment, and we reserve the right to amend it at any time.
2. Responsibility for the Policy
2.1 The board of directors holds overall responsibility for ensuring compliance with our legal and ethical obligations, and for ensuring that all individuals under our control adhere to this policy.
2.2 The Compliance Supervisor is responsible for the day-to-day implementation, monitoring, and effectiveness of this policy, addressing any queries, and auditing internal control systems and procedures to ensure they effectively counter modern slavery.
2.3 Managers at all levels must ensure their direct reports understand and comply with this policy, and are provided with adequate and regular training on modern slavery issues within supply chains.
2.4 We welcome comments and suggestions for improving this policy. Feedback should be directed to the Compliance Supervisor.
3. Compliance with the Policy
3.1 You must read, understand, and comply with this policy.
3.2 The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is a collective responsibility. You must avoid any actions that could lead to a breach of this policy.
3.3 Notify your manager or the Compliance Supervisor immediately if you believe or suspect a conflict with this policy has occurred or may occur.
3.4 We encourage you to raise concerns about any suspected modern slavery issues in any part of our business or supply chains as soon as possible.
3.5 If you believe or suspect a breach of this policy has occurred or may occur, report it to your manager or Managing Director, or follow our Whistleblowing Policy. We may provide support and guidance to suppliers to address coercive or exploitative practices in their operations and supply chains, prioritizing the welfare and safety of local workers.
3.6 If you are unsure whether an action or treatment of workers constitutes modern slavery, consult your manager, Managing Director, or use the confidential helpline.
3.7 We aim to foster 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 detrimental treatment for reporting concerns about modern slavery. Detrimental treatment includes dismissal, disciplinary actions, threats, or other adverse treatment related to raising a concern. If you believe you have faced such treatment, inform the Compliance Supervisor immediately. If unresolved, employees should formally raise the issue using our Grievance Procedure, detailed in the Operations Manual.
4. Communication and Awareness of This Policy
4.1 Training on this policy and the risks of modern slavery in our supply chains is part of the induction process for all individuals working for us. Ongoing training will be provided as needed.
4.2 Our zero-tolerance stance on modern slavery must be communicated to all suppliers, contractors, and business partners at the start of our business relationship and reinforced as necessary.
5. Breaches of This Policy
5.1 Employees who breach this policy will face disciplinary actions, which could result in dismissal for misconduct or gross misconduct.
5.2 We may terminate our relationships with individuals and organizations working on our behalf if they breach this policy.