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. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own organisation or in any of our supply chains.
1.2 We are also committed to ensuring there is transparency in our own organisation and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and 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, whether adults or children and we expect that our suppliers will hold their own suppliers to the same high standards.
1.3 The purpose of this policy is to:
a) set out our responsibilities, and of those working for and on our behalf, in observing and upholding our position on modern slavery and human trafficking; and
b) provide information to those working for and on our behalf on how to identify and report concerns regarding modern slavery and human trafficking.
2. WHO IS COVERED BY THE POLICY?
2.1 This policy applies to all employees, directors and other officers, workers and agency workers, volunteers and interns.
2.2 We also require in any contracts with self-employed consultants or contractors, third party representatives and business partners, sponsors and any other person associated with us, that they comply with this policy. We will ensure they are given access to a copy.
3.HWHO IS RESPONSIBLE FOR THIS POLICY?
3.1 The Directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
4. EMPLOYEE RESPONSIBILITIES AND HOW TO RAISE A CONCERN
4.1 All employees must ensure that they read, understand and comply with this policy.
4.2 The prevention, detection and reporting of modern slavery in any part of our organisation or supply chains is the responsibility of all those working for us or under our control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
4.3 An employee must notify their manager or Director as soon as possible if they believe or suspect that a breach of this policy has occurred or may occur in the future.
4.4 Employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our organisation or supply chains of any supplier tier at the earliest possible stage.
4.5 If an employee believes or suspects a breach of this policy has occurred or that it may occur, you must notify their manager or Director or report it in accordance with our Whistleblowing Policy as soon as possible.
4.6 If an employee is 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, they are encouraged to raise it with their manager or Director.
4.7 We aim 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. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own organisation or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavorable treatment connected with raising a concern. If you believe that an employee believes they have suffered any such treatment, they should inform your manager immediately. If the matter is not remedied and you are an employee, you should raise it formally using our Grievance procedure.
5.BTRAINING AND COMMUNICATION
5.1 Training on this policy, and on the risk our organisation faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.w
5.2 Our commitment to addressing the issues of modern slavery in our business and supply chains must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
6. BREACHES OF THIS POLICY
6.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
6.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
7.GMONITORING AND REVIEW OF THE POLICY
7.1 We will continue to review the effectiveness of this policy to ensure it is achieving its stated objectives.
