Anti-Slavery and Human Trafficking Policy
1. Policy statement
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 dealing and relationships and to implementing and enforcing
effective systems and controls to ensure modern slavery is not taking place
anywhere in our group.
1.2 We are also committed to ensuring there
is transparency in our own businesses in our approach to tackling modern
slavery throughout, 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, agency workers, contractors, external consultants and 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. Responsibility for the 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 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
2.3 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.
2.4 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.
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 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 or the
compliance officer 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 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 or
report it to the compliance officer at the earliest possible opportunity.
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 suppliers constitutes any of the various
forms of modern slavery, raise it with your manager or the compliance officer.
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 group. 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 officer immediately. If the matter is not remedied, and
you are an employee, you should raise it formally using the business 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, 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. Breaches 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.
Andrew Hobkirk
Managing Director
1st October 2023