Modern Slavery and Human Trafficking Policy

1. Policy statement

a. Policy statementModern slavery is a crime and a violation of fundamental human rights. It takes variousforms, 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 toexploit them for personal or commercial gain. We have a zero-tolerance approach tomodern slavery and we are committed to acting ethically and with integrity in all ourbusiness dealings and relationships and to implementing and enforcing effectivesystems and controls to ensure modern slavery is not taking place anywhere in our ownbusiness or in any of our supply chains.

b. We are also committed to ensuring there is transparency in our own business and in ourapproach to tackling modern slavery throughout our supply chains, consistent with ourdisclosure obligations under the Modern Slavery Act 2015. We expect the same highstandards from all of our contractors, suppliers and other business partners, and as partof 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 orchildren, and we expect that our suppliers will hold their own suppliers to the same high standards.

c. 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 representativesand business partners.

d. This policy does not form part of any employee's contract of employment and we mayamend it at any time.


2. Responsibility for the policy

a. ENTER JOB TITLE has overall responsibility for ensuring this policy complies with ourlegal and ethical obligations, and that all those under our control comply with it.

b. ENTER JOB TITLE has primary and day-to-day responsibility for implementing thispolicy, monitoring its use and effectiveness, dealing with any queries about it, andauditing internal control systems and procedures to ensure they are effective incountering modern slavery.

c. Line managers at all levels are responsible for ensuring those reporting to themunderstand and comply with this policy and are given adequate and regular training on itand the issue of modern slavery in supply chains.

d. You are invited to comment on this policy and suggest ways in which it might beimproved. Comments, suggestions and queries are encouraged and should beaddressed to the person responsible for this policy.


3. Compliance with the policy

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

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

c. You must notify your manager as soon as possible if you believe or suspect that aconflict with this policy has occurred, or may occur in the future.

d. You are encouraged to raise concerns about any issue or suspicion of modern slavery inany parts of our business or supply chains of any supplier tier at the earliest possiblestage.

e. If you believe or suspect a breach of this policy has occurred or that it may occur youmust notify your manager or report it in accordance with our Whistleblowing Policy assoon as possible.

f. If you are unsure about whether a particular act, the treatment of workers moreIf you are unsure about whether a particular act, the treatment of workers moregenerally, or their working conditions within any tier of our supply chains constitutes anyof the various forms of modern slavery, raise it with your manager or Head ofProcurement.

g. We aim to encourage openness and will support anyone who raises genuine concerns ingood faith under this policy, even if they turn out to be mistaken. We are committed toensuring no one suffers any detrimental treatment as a result of reporting in good faiththeir suspicion that modern slavery of whatever form is or may be taking place in anypart of our own business or in any of our supply chains. Detrimental treatment includesdismissal, disciplinary action, threats or other unfavourable treatment connected withraising a concern. If you believe that you have suffered any such treatment, you shouldinform the Head of Procurement immediately. If the matter is not remedied, and you arean employee, you should raise it formally using our Grievance Procedure.


4. Communication and awareness of this policy

a. Training on this policy, and on the risk our business faces from modern slavery in itssupply chains, forms part of the induction process for all individuals who work for us, andregular training will be provided as necessary.

b. 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 themand reinforced as appropriate thereafter.


4. Breaches of this policy

a. Any employee who breaches this policy will face disciplinary action, which could result indismissal for misconduct or gross misconduct.

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



Download the policy as pfd document here.


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