Modern Slavery Policy

    The purpose of this policy is to communicate and establish controls to ensure compliance with all Anti-slavery and Human trafficking regulations as well as ensuring alignment to the Company ethics and Code of Conduct.
  2. SCOPE
    1. The policy covers all employees, suppliers and third-party providers and is intended to ensure all are aware of the responsibilities they hold.
    2. Our Board has overall accountability for ensuring that this policy complies with our legal and ethical obligations, and that all our people comply with it.
    3. The Compliance team is responsible for the policy implementation and appropriate communication of this policy to all relevant employees together with associated training programmes.
    4. All enquiries or concerns regarding this policy should be communicated to the Compliance officer.
    5. All employees must comply with this policy. We have a recruitment and selection policy to assist compliance with equal opportunity.
    6. All suppliers and third-party providers must comply with this policy.
    1. “Modern slavery” is a term which covers slavery (where ownership is exercised over a person); servitude (which involves the obligation to provide services imposed by coercion); forced or compulsory labour (which involves work or service exacted from any person under the menace of a penalty and for which the person has not offered himself voluntarily); and human trafficking (which concerns arranging or facilitating the travel of another with a view to exploiting them, even where the person consents to the travel).
    2. We will ensure that we will comply with the Modern Slavery Act 2015 and are putting strict measures in place to ensure that modern slavery is not part of any of our business operations. This includes our supply chains, goods, and services. This statement sets out the steps we are taking to continually develop our procedures and to check our compliance.
    3. Modern Slavery is a crime and a violation of fundamental human rights. It is a term used to encompass slavery, servitude, forced compulsory labour, bonded and child labour and human trafficking, all of which include the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
    1. There is no typical victim of Modern Slavery, and some victims do not understand that they have been exploited and are entitled to help and support. However, the following key signs could indicate that someone may be a victim of Modern Slavery or human trafficking:
      • • The person is not in possession of their own passport, identification, or travel documents;
      • • The person is acting as though they are being instructed or coached by someone else;
      • • The person allows others to speak for them when spoken to directly;
      • • The person is dropped off and collected from work;
      • • The person avoids eye contact, is withdrawn or appears frightened;
      • • The person does not seem to be able to contact friends or family freely;
      • • The person has limited social interaction or contact with people outside of their immediate environment.

      The above list is not exhaustive. A person may display a number of the indicators set out above, but they may not necessarily be a victim of slavery or trafficking.

    1. Our policy does not allow for any form of slavery or human trafficking, and we will take proactive steps to ensure that Modern Slavery is not taking place in any part of our business.
    2. We will not engage with organisations which facilitate any form of slavery including the use of child labour or forced labour, or which do not recognise freedom of association or collective bargaining.
    3. We require that the suppliers and third parties we work with should hold their own suppliers and third parties to the same standards.
    4. We seek to continually improve awareness of the practices necessary to combat slavery and human trafficking and assess the risk profile of our business in these areas.
    5. Our zero-tolerance approach to Modern Slavery includes our commitment that:
      • • All employees (including but not limited to; permanent, temporary, full time, part time) as well as contractors and internships, will have a contract of employment, will be paid minimum wage in line with the National Minimum Wage Act 1999 and their working hours will comply with within the working time directive.
      • • we will comply with the Employment Rights Act 1996.
      • • we will not allow any form of slavery or human trafficking to take place in any part of our business;
      • • we will not use child labour, nor will we use forced labour;
      • • we recognise freedom of association by permitting our employees to establish and join organisations of their own choosing without our permission;
      • • we will recognise collective bargaining where required by local laws;
      • • we will comply with all relevant laws, statutes and regulations relating to modern slavery;
      • • we will publish Modern Slavery Statements in accordance with the relevant legislation;
      • • we require our suppliers and third-party providers to comply with the above; and to hold their own suppliers and third parties to the same standards;
      • • we will seek to educate and raise awareness across our business in the identification and reporting of Modern Slavery.
    1. The prevention, detection and reporting of Modern Slavery in any part of our business is the responsibility of all those working within it.
    2. 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, business partners and suppliers. We expect the highest standards of compliance to be upheld at all times.
    3. We have a robust governance structure in place and take a risk-based approach to our contracting processes which are then kept under review. Suppliers or proposed suppliers are provided with our Code of conduct, which is a part of our agreements, and we clearly communicate compliance as part of the minimum standards of doing business with us.
    4. If we find that other individuals or organisations working on our behalf have breached this policy, we will ensure that we take appropriate action. Any employee who breaches this policy may face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
    5. If a supplier or third-party provider is found to be in breach of this policy, we may terminate our relationship and any contract or purchasing agreement in place.
    1. Employees, suppliers, and third-party providers must not engage in, facilitate, or fail to report any activity that might lead to, or suggest, a breach of this policy.
    2. If you are an employee, you must report any incidence or suspicion of Modern Slavery and/or human trafficking in any part of our business to your Line Manager, and Compliance Officer, or the Operations Director.
    3. If you are a supplier or third-party provider to the Company, you should report any suspicion to your primary business contact.
    4. Reports are treated in accordance with our confidentiality policy, acknowledged and acted upon as appropriate.
    All suppliers are issued with our Code of Conduct and are required to sign and return a commitment to ensuring that they take appropriate steps to ensure that their businesses are free from modern slavery prior to any orders being placed with them.
    1. If a supplier is found to be involved in any form of modern slavery, its contract will be terminated either immediately or on its due renewal date, depending on the severity of the breach and we may also report any suspicions of criminal activity to the police.
    2. If it is established that any employee has acted in breach of any of our policies, or is aware of, has condoned or failed to report any suspicion of modern slavery within our business or supply chains, they will be subject to our disciplinary procedure.
    We will provide suitable training for all employees to ensure that they are aware of this policy and can be vigilant in identifying and reporting any concerns they have.