MODERN SLAVERY & HUMAN TRAFFICKING POLICY
Policy Statement
Modern slavery is a crime resulting in an abhorrent abuse of the human rights of vulnerable workers, including children.
It can take various forms, such as slavery, servitude, forced or compulsory labour and human trafficking.
The Company has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity
and transparency in all of its business dealings and relationships and to implementing and enforcing effective
systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within
either its own business or in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015.
The Company also expects the same high standards from all its suppliers, contractors and other business partners
and includes specific prohibitions against the use of modern slavery as part of its contracting processes.
The Company recognises that identifying victims of modern slavery can be challenging, as the crime can take many
forms and may be concealed by suppliers. The Company therefore accepts responsibility to carry out reasonable
and practical due diligence to ensure workers are not exploited and that employment, health and safety, and
human rights laws are upheld.
This policy applies to all individuals working for or on behalf of the Company in any capacity, including employees,
directors, officers, agency workers, volunteers, agents, contractors, consultants, and business partners.
Responsibility for the Policy
The Directors have overall responsibility for ensuring that this policy complies with the Company’s legal and ethical
obligations. All staff are responsible for implementing this policy, monitoring its effectiveness, and reporting
concerns.
Line managers are responsible for ensuring that individuals reporting to them understand and comply with this policy.
Compliance
The prevention, detection, and reporting of modern slavery in any part of the Company’s business or supply chains
is the responsibility of all individuals working for or under the control of the Company.
You must avoid any activity that may lead to a breach of this policy. If you suspect or believe a breach has occurred
or may occur, you must notify your line manager or report it in accordance with the Company’s Disclosures in the
Public Interest Policy.
Concerns may also be raised with the UK Government’s Modern Slavery Helpline on 0800 0121 700.
The Company supports all individuals who raise concerns in good faith and ensures that no one suffers detrimental
treatment or victimisation for doing so.
Training and Communication
Regular training will be provided to staff to ensure awareness of modern slavery risks and how to identify and
report suspected cases.
The Company’s zero-tolerance approach will be communicated to all suppliers, contractors, and business partners.
Breach of the Policy
Any employee who breaches this policy may face disciplinary action, including summary dismissal for gross misconduct.
The Company may terminate relationships with suppliers or partners found to be involved in modern slavery.
