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.
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.
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.
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.
This policy does not form part of any employee's contract of employment
and we may amend it at any time.
Responsibility for the Policy
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.
The office 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 office manager.
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 for
us or 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 office manager as soon as
possible if you believe or suspect that a conflict with 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 notify your manager or report it in accordance with
our Whistleblowing Policy as soon as possible. You should note that
where appropriate, and with the welfare and safety of local workers as a
priority, we may give support and guidance to our suppliers to help them
address coercive or exploitative work practices in their own business and
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 or office 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. 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 which can be found in our Employee Handbook.
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
Our commitment to addressing the issue of modern slavery in our
business and supply chains must be communicated to all suppliers,
contractors and business partners at the outset of our 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.