Anti Slavery and Human Trafficking Policy
1. POLICY STATEMENT
1.1 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.
1.2 We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all of our business dealings and relationships. We are committed 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.
1.3 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery consistent with the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners.
1.4 This policy 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.
1.5 This policy does not form part of any employees contract of employment and we may amend it at any time.
2. RESPONSIBILITY FOR THE POLICY
2.1 The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
2.2 The board also has primary and day-to-day responsibility for implementing this policy, monitoring it’s use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modelling slavery.
2.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
2.4 You are invited to comment o this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to your line manager.
3. COMPLIANCE WITH THE POLICY
3.1 You must ensure that you read, understand and comply with this policy.
3.2 The prevention, detection snd 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.
3.3 You must notify your manager as soon as possible id you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
3.4 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.
3.5 If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager as soon as possible.
3.6 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 manager.
3.7 We aim to encourage openness and 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 slaver of whatever form is or may be taking place in any part of our own business or any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe you have suffered such treatment, you should inform your line manager or director immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our grievance procedure.
3.8 Any person working for our business or as a supplier or contractor to our business who is found to be engaging in slavery or human trafficking will de disciplined or the relationship terminated and will also be reported to the relevant authority.
4. AWARENESS OF THIS POLICY
4.1 The risk our business faces from modern slavery in it’s supply chains forms part of all our responsibility to be aware of for all individuals who work for us. All of our employees should ensure they are familiar with this policy.
4.2 We aim to communicate our zero-tolerance approach to modern slavery to all suppliers, contractors and business partners at the outset of our business relationship with them and to be reinforced as appropriate thereafter.
5. BREACHES OF THIS POLICY
5.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
5.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.