Modern slavery, including human trafficking, forced labour, and bonded labour, is a serious crime and an egregious violation of fundamental human rights. It involves the exploitation of individuals through the deprivation of their liberty for personal or commercial gain.
We are firmly committed to conducting all of our business operations with the utmost integrity and transparency. We aim to ensure that modern slavery has no place in our business, its subsidiaries, or any part of our supply chains. This policy reinforces our commitment to ethical conduct and social responsibility in accordance with the Modern Slavery Act 2015 and other relevant legislation.
In support of this commitment, we have implemented measures to identify and mitigate the risks of modern slavery and human trafficking across all aspects of our operations and supply chains. We expect the same high standards from all our partners, suppliers, and subcontractors.
This policy applies to all individuals working for the company, including:
● Employees at all levels
● Directors and officers
● Agency workers
● Temporary and seconded workers
● Interns
● Contractors and consultants
● External third-party representatives
● Business partners and suppliers
Our zero-tolerance approach to modern slavery extends to all third-party relationships, including
suppliers and partners across our global supply chains.
Responsibility for the Policy
Overall Responsibility:
The senior management of the company holds overall responsibility for ensuring that this policy complies with legal and ethical standards, and that it is fully implemented across all areas of the business.
Operational Responsibility:
Day-to-day responsibility for implementing this policy lies with the directors, in conjunction with business unit leads, who are responsible for reviewing and assessing the risks within our supply chain. These individuals will ensure that all necessary procedures and practices are in place to prevent instances of modern slavery.
Audit and Risk Management:
We have developed and implemented a robust audit process to regularly evaluate the effectiveness of our anti-slavery measures. Business unit leads and procurement teams will assess and monitor our suppliers, ensuring that their operations adhere to the same high ethical standards. Any identified risks will be escalated and dealt with in a timely and effective manner.
Identifying and Managing Risk
To effectively manage the risk of modern slavery, we have implemented the following measures:
1. Due Diligence:
○ We conduct thorough due diligence on all new and existing suppliers, partners, and contractors. This includes reviewing their labour practices, workplace conditions, and compliance with relevant laws and regulations.
○ Contracts with suppliers include specific provisions requiring adherence to anti-slavery policies and procedures.
○ We assess geographic and sector-specific risks, particularly in regions or industries known for higher instances of forced labour or trafficking.
2. Supplier Audits:
○ Periodic audits are conducted across our supply chain to identify any potential risks of modern slavery or unethical labour practices. These audits may include site visits, review of records, and employee interviews.
○ Any concerns identified during audits are addressed through corrective action plans, which are monitored for effective resolution.
3. Risk Assessment:
○ We regularly review our supply chain for risk factors related to modern slavery, including the use of low-cost labour, lack of regulatory oversight, or reliance on labour recruitment agencies.
○ Higher-risk suppliers may be subject to more frequent audits and stricter contractual obligations.
4. Training:
○ All employees, particularly those involved in procurement, supply chain management, and HR, receive ongoing training to recognize the signs of modern slavery and human trafficking.
○ Training ensures that employees understand the company’s expectations for ethical behaviour and are equipped to act if they identify suspicious activity.
Compliance with the Policy
Employee Responsibilities:
It is the duty of all employees and those working on behalf of the company to adhere to this policy and ensure that modern slavery does not occur in any part of our business or supply chain.
● You must avoid any activity that may lead to a breach of this policy.
● If you suspect any form of modern slavery within the business or its supply chains, you must report it immediately to your line manager or use the company’s Whistleblowing Policy.
● Employees are encouraged to seek advice from the legal department or compliance team if unsure whether certain practices breach this policy.
Reporting Concerns:
If you believe there is a potential risk of modern slavery or human trafficking in any part of the business, you are required to report your concerns through the following methods:
● Internal Reporting: Speak directly to your line manager or use the company’s established whistleblowing procedure.
● Confidentiality: We will handle all reports confidentially and take every concern seriously, with a thorough investigation to follow. We encourage openness and will support anyone raising concerns in good faith, even if their concerns are mistaken. We are committed to ensuring that no one suffers retaliation, discrimination, or any form of detrimental treatment for reporting suspected modern slavery.
Communication and Awareness
Internal Communication:
This policy is communicated to all employees during onboarding and is made available via the company intranet. Updates or revisions to the policy will be communicated promptly. All employees must complete mandatory training on modern slavery awareness and compliance.
External Communication:
Our zero-tolerance approach to modern slavery is communicated to all significant suppliers, contractors, and business partners at the outset of our business relationship and reaffirmed regularly. Suppliers are contractually obligated to adhere to this policy, and failure to comply may result in the termination of contracts or business relationships.
Breach of Policy
Consequences for Employees:
Any employee found to be in breach of this policy may face disciplinary action, up to and including dismissal for misconduct or gross misconduct.
Consequences for Third Parties:
If any supplier, contractor, or business partner is found to be in breach of this policy, we will take immediate steps to address the violation, which may include terminating our relationship with the offending party.
Review and Updates
This policy will be reviewed annually or in response to changes in legal requirements or business practices. Any changes to the policy will be approved by senior management and communicated accordingly.
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