Anti- Modern Slavery and Human Trafficking Policy

​Introduction

The Company has a zero-tolerance approach to modern slavery and is committed to acting ethically, with integrity and transparency in all of its business dealings and relationships.

The Company is committed 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. The Company endeavours to be 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, as part of its contracting processes, it includes specific prohibitions against the use of modern slavery and expects that its suppliers will in turn hold their own suppliers to the same standards.

The policy applies to all individuals working for the Company or on the Company’s behalf in any capacity, including employees, Directors, officers, agency workers, volunteers, agents, contractors, consultants and business partners.

 

Scope

Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many different ways.

Some suppliers may go to great lengths to hide the fact they are using slave labour. However, the Company accepts that it has a responsibility through its due diligence processes to ensure that workers are not being exploited, that they are safe, and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.

 

Responsibilities

The Managing Directors have overall responsibility for ensuring that this policy complies with the Company’s legal and ethical obligations.

They are also responsible for investigating allegations of modern slavery in the Company’s business or supply chains.

Managers are responsible for ensuring that those reporting to them understand and comply with this policy.

 

Compliance responsibilities

The prevention, detection and reporting of modern slavery in any part of the Company’s business or supply chains, whether in the UK or abroad, is the responsibility of all those working for the Company or under the Company’s control. You are required to avoid any activity that might lead to a breach of this policy.

The Company encourages anyone to raise concerns about any issue or suspicion of modern slavery in any part of the Company’s business or supply chains as soon as possible. If you are unsure about whether a particular act, the treatment of workers or their working conditions within any of the Company’s supply chains constitutes any of the various forms of modern slavery.

The Company is committed to ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of its business or in any of its supply chains.

 

Protective measures

The Company is committed to:

• Paying people fairly and properly for their work.

• Transparent and fair behaviour, such as protecting human rights.

• Compliance with legislation, including fundamental rights at work including elimination of discrimination throughout employment.

• Ensuring all work carried out by staff and those associated with the Company is voluntary, and not done under any threat of penalties.

The prevention, detection and reporting of modern slavery is the responsibility of all those working for the Company or associated with the Company. Staff and those associated with the Company are required to avoid any activity that might lead to a breach of this policy.

 

Breach of this policy

The Company may terminate its commercial relationship with suppliers, contractors and other business partners is they breach this policy and/or are found to have been involved in modern slavery.

 

For any information regarding this policy, please contact us.