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Anti-Slavery and Human Trafficking Policy

1. POLICY STATEMENT

We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealing and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or within our supply chains.

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 our Contractors and Suppliers, 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.

The company will achieve these aims by our initiative to identify and mitigate risk in the following ways (but not limited to):-

  • More stringent vetting and investigation of our supply chain (contractors, sub-contractors, policies, contracts etc.)
  • Continually audit and review our practices for checking all employees are paid at least the minimum wage, and have the right to work
  • We encourage the reporting of concerns and the protection of whistle blowers
  • The company will not knowingly support or deal with any business involved in slavery or human trafficking
  • We have a zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors to comply with our values.

This policy applies to all persons working for us or on our behalf in any capacity, including Employees at all levels, Directors, agency workers, seconded workers, volunteers, agents, contractors, external consultants, third-party representatives and business partners.

This policy does not form part of any employee’s contract of employment and we may amend it at any time.

  1. RESPONSIBILITY FOR THE POLICY

The Board of Directors have overall responsibility for ensuring this policy compiles with our legal and ethical obligations, and that all those under our control comply with it.

The Compliance Manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

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.

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 the Compliance Manager.

  1. COMPLIANCE WITH THE POLICY

You must ensure that you read, understand and comply with this policy.

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

You must notify your manager or the compliance manager as soon as possible if you believe or suspect that a conflict of this policy has occurred, or may occur in the future.

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.

If you believe or suspect a breach of this policy has occurred or that it may occur, you must report it in accordance with our ‘Whistle Blowing Statement’, which can be found within our Harassment and Bullying Policy.

If you are unsure as to whether a particular act, the treatment of Workers 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 or the Compliance Manager.

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.

COMMUNICATION AND AWARENESS OF THIS POLICY

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.

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of business relationship with them and reinforced as appropriate thereafter.

BREACHES OF THIS POLICY

Any Employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Our financial year ends 30th September.

This policy will be regularly reviewed (minimum annually).