This policy supports our commitment to limiting the risk of modern slavery occurring within our own business or infiltrating our supply chains or any other business relationship.
The policy applies to all persons working for or on our behalf in any capacity, including employees, directors, officers, agency workers, contractors, consultants, work experience, apprentices and any other third party representative.
We expect all who have, or seek to have a business relationship with the company to familiarise themselves with this policy and to act at all times in a way that is consistent with its values.
We will only do business with organisations who fully comply with this policy or those who are taking verifiable steps towards compliance.
This policy will be used to underpin and inform any statement on slavery and human trafficking that we are required to produce further to the transparency in supply chain requirements of Section 54 of the Modern Slavery Act 2015 (MSA).
Modern slavery can take many forms. It is a complex and multi-faceted problem. The MSA covers four key criminal activities:
Slavery: where ownership is exercised over an individual
Servitude: involves the obligation to provide service imposed by coercion
Forced and compulsory labour: all work or service, not voluntarily performed, which is obtained from an individual under the threat of force or penalty.
Human trafficking: involves arranging or facilitating the travel of another with a view to exploiting them
Other forms of modern slavery, which we will not tolerate, but are not specifically referenced in the MSA include, but are not limited to:
Child labour: whilst not always illegal in the jurisdiction in which it takes places, child labour involves the employment of children that is exploitative, or is likely to be hazardous to, or interfere with, a child’s education, health (including mental health), physical wellbeing or social development.
All forms of modern slavery have in common the deprivation of a person’s liberty by another in order to exploit them for commercial or personal gain and amount to a violation of an individual’s fundamental human rights.
Tackling modern slavery requires us all to play a part and remain vigilant to the risk in all aspect of our business and business relationships.
To underpin our policy commitments, we have implemented the following measures over the course of the financial year 2019/2020:
The board of Directors has overall responsibility for this policy and in ensuring that the Company complies with all its legal and ethical obligations.
The Vice President of HR will have the primary day-to-day responsibility for the implementation of this policy, monitoring its use and ensuring that the appropriate processes and control systems are in place, and amended as appropriate, to ensure it can operate effectively.
All Line Mangers are responsible for ensuring that those reporting directly to them comply with the provisions of this policy in the day-to-day performance of their roles.
The Vice President of HR will ensure that all relevant staff receive adequate training on this policy and any supporting processes applicable to their role.
In addition, staff will receive training on the broader issues of modern slavery to assist them in appreciating the extent of the problem of modern slavery and the identify individuals/areas of the business that may be at risk from practices of modern slavery.
Any breaches of this policy will be taken seriously and dealt with on a case-by-case basis.
The breach of this policy by an employee, Director or officer of the company may lead to disciplinary action being taken in accordance with our disciplinary procedure. Serious breaches may be regarded as gross misconduct and may lead to immediate dismissal in line with our disciplinary procedure.
Everybody to whom this policy applies will be expected to fully co-operate in any investigation into suspected breaches of this policy or any related processes or procedures.
If any part of this policy is unclear, clarification should be sought from the Vice President of HR.
This Anti-slavery policy will be reviewed by the Company’s board of Directors on a regular basis at the start of each financial year.
This policy does not give contractual rights to company employees, and we reserve the right to alter any of its terms at any time. We will notify applicable parties in writing of any changes which may affect them.
This statement was approved by the Board on 9th August 2021.