Anti-Slavery and Human Trafficking Policy
Purpose
The purpose of this policy is to set out the Company’s responsibilities, and those of employees and suppliers, in observing and upholding our zero-tolerance position on modern slavery and human trafficking.
Scope
This policy applies to all individuals working for the Company or on its behalf, at all levels, including directors, senior managers, employees, contractors, agency staff, volunteers, interns and business partners.
Our Commitments
- We have a zero-tolerance approach to modern slavery and human trafficking in all its forms.
- We are committed to acting ethically and with integrity in all our business dealings and relationships.
- We will implement and enforce effective systems and controls to ensure modern slavery and human trafficking are not taking place in our own business or in any of our supply chains.
- We will ensure transparency in our business and approach to tackling modern slavery, consistent with our disclosure obligations under the Modern Slavery Act 2015.
Responsibilities
Management
- Ensure that appropriate due diligence is carried out on suppliers, contractors and business partners.
- Communicate this policy to all employees and relevant external parties.
- Provide training where necessary to help staff understand and comply with this policy.
Employees
- Read, understand and comply with this policy.
- Remain alert to the risks of modern slavery and human trafficking, particularly in supply chains.
- Report concerns about any issue or suspicion of modern slavery in any part of the business or supply chain at the earliest possible stage.
Due Diligence
The Company will take steps to identify and mitigate the risk of slavery and human trafficking by:
- Carrying out risk assessments of new suppliers and contractors.
- Including compliance with the Modern Slavery Act 2015 as a contractual requirement in supplier agreements.
- Monitoring suppliers and contractors through regular reviews and audits where proportionate.
Raising Concerns
Employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of the business or supply chain. Concerns should be reported to a line manager or [insert role, e.g. HR Manager / Compliance Officer]. Reports will be taken seriously, investigated appropriately and treated confidentially where possible.
Breaches of this Policy
Any employee who breaches this policy may face disciplinary action, which could result in dismissal for misconduct or gross misconduct. The Company may terminate its relationship with other individuals or organisations working on its behalf if they are found to be in breach of this policy.
Review
This policy will be reviewed annually and updated where necessary to ensure it continues to comply with the Modern Slavery Act 2015 and reflect best practice.