Anti-Slavery Policy

Date: 25/09/2020

What are the aims of this policy?

This policy supports our commitment to limiting the risk of modern slavery within our own business or our supply chains, or any other business with which we have relationship. The policy applies to all persons working for, or on behalf of, our business, including employees, directors, officers, agency workers, contractors, consultants, and any other third-party representative. We expect all companies and individuals who have, or seek to have, a business relationship with our business to familiarise themselves with this policy, and to act at all times in a way that is consistent with its values. This policy will be used to underpin and inform any statement on slavery and human trafficking that we may be required to produce further to the transparency in supply chain requirements of Section 54 of the Modern Slavery Act 2015 (MSA).

What do we mean by modern slavery?

Modern slavery can take many forms. The MSA covers four key criminal activities:

·       Slavery: where ownership is exercised over an individual

·       Servitude: where an individual is coerced to provide service

·       Forced and compulsory labour: where work or service is obtained from an individual under the threat of force or penalty, not voluntarily

·       Human trafficking: where a perpetrator is involved with arranging or facilitating the travel of another with a view to exploiting them

Furthermore, although not specifically referenced in the MSA, we will not tolerate Child labour. Whilst not always illegal in the jurisdiction in which it takes places, child labour involves the employment of children that is exploitative, or is likely to be hazardous to, or interfere with, a child’s education, health (including mental health), physical well-being or social development.

All forms of modern slavery involve depriving a person of their liberty, to exploit them for commercial or personal gain, and are a violation of their fundamental human rights. Tackling modern slavery requires us all to play a part and remain vigilant to the risk in all aspect of our business and business relationships.

What will we do in practice?

To deliver our policy commitments, we will undertake the following:

·       Conduct risk assessments to determine risks of modern slavery in our business and our supply chains.

·       In accordance with the risk assessment, inform our suppliers of our anti-slavery policy and understand their measures against modern slavery (and, where appropriate, agree how such measures could be improved).

Who has responsibility for this policy?

The Director has responsibility for this policy, ensuring that our business complies with all legal and ethical obligations.

All Managers with reporting staff have day-to-day responsibility for policy implementation, monitoring and ensuring appropriate checks and processes are present and up to date, to ensure its effectiveness. All Managers have responsibility for the compliance of those reporting to them.

All relevant staff will receive training on this policy and any related processes applicable to their role. Such training will form part of our induction process.

Any breaches of this policy will be taken seriously and dealt with on a case by case basis. This may lead to disciplinary action being taken. Serious breaches may be regarded as gross misconduct and may lead to immediate dismissal. Everybody will be expected to fully co-operate with any investigation into suspected breaches of this policy, or any related processes or procedures. If any part of this policy is unclear, clarification should be sought from the Director.

What is the status of this policy?

This policy will be reviewed as required. Our business has the right to alter any of its terms at any time. The latest version will always be available on request from the Director.