1. ABOUT THIS POLICY
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 have a zero-tolerance approach to
modern slavery and 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
or in any of our supply chains.
1.2 We are also committed to ensuring there is transparency in our own business 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 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.
1.4 This policy does not form part of any employee’s contract of employment and we may
amend it at any time.
2. PERSONNEL RESPONSIBLE FOR THIS 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 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.
2.3 You are invited to comment on this policy and suggest ways in which it might be
improved. Comments, suggestions and queries are encouraged and should be addressed
to your 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 and 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 if 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. You should note that where appropriate,
and with the welfare and safety of local workers as a priority, we will give support and
guidance to our suppliers to help them address coercive, abusive and exploitative work
practices in their own business and supply chains.
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 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 business or in any of our supply chains. Detrimental treatment includes
dismissal, disciplinary action, threats or other unfavourable treatment connected with
raising a concern. If you believe that you have suffered any such treatment, you should
inform the compliance manager immediately. If the matter is not remedied, and you are
an employee, you should raise it formally using our Grievance Procedure.
4. COMMUNICATION AND AWARENESS OF THIS POLICY
4.1 Training on this policy, and on the risk our business 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.
4.2 Our zero-tolerance approach to modern slavery must be communicated to all suppliers,
contractors and business partners at the outset of our business relationship with them
and reinforced as appropriate thereafter.
5. BREACH 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
