Modern Slavery and Human Trafficking Policy

Policy Statement

This Policy sets down our Company commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.

Modern Slavery and Human Trafficking

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights (Modern Slavery Act 2015).

Commitments

We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

  1. We have a zero-tolerance approach to modern slavery in our Company and supply chains.
  2. The prevention, detection and reporting of modern slavery in any part of our Company or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
  3. We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our Company and supply chain.
  4. We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties.
  5. Consistent with our risk-based approach we may require:
    5.1 – Employment and recruitment agencies and other third parties supplying workers to our Company to confirm their agreement to comply with the commitments outlined in this Policy.
    5.2  – Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the commitments outlined in this Policy.
  6. As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of suppliers for their agreement to comply with this Policy.
  7. If we find that other individuals or organisations working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.