Policy Statement
Modern slavery is a grave violation of human rights that includes slavery, servitude, forced labor, and human trafficking. It deprives individuals of their freedom and is used for personal or commercial exploitation. We are committed to operating with the highest ethical standards and integrity, ensuring that modern slavery is not present in any part of our business or supply chains.
Our commitment extends to maintaining transparency in both our own business and our supply chains, aligning with the disclosure obligations set forth under the Modern Slavery Act 2015. We expect all our contractors, suppliers, and business partners to uphold the same principles.
This policy applies to all individuals working for us, whether employees, directors, agency workers, contractors, consultants, volunteers, interns, or third-party business partners.
This policy does not form part of any individual’s contract of employment and may be amended at any time.
Our Business
Compliance with the Policy
It is the responsibility of everyone within our organization to read, understand, and comply with this policy. Prevention, detection, and reporting of modern slavery in our business and supply chains are essential duties for all involved in our operations. Any activity that may lead to, or suggest, a breach of this policy must be avoided.
If you suspect that modern slavery may be occurring within our business or in any tier of our supply chains, you must report it immediately to your manager, a director, or in accordance with our Whistleblowing Policy. We are committed to maintaining a culture of openness and support for those who raise concerns in good faith, even if those concerns turn out to be unfounded.
Employees or associates who report concerns in good faith will be protected from any form of detrimental treatment, including dismissal or disciplinary action. If any individual feels they have experienced such treatment, they should notify the compliance manager without delay. If the issue is not resolved, employees are encouraged to follow our formal resolving issues procedure.
Due Diligence Process for Slavery and Human Trafficking
We take proactive steps to prevent and detect modern slavery within our operations and supply chains. This includes comprehensive due diligence processes, with the aim to ensure that no part of our business or supply chain engages in slavery or human trafficking practices.
Breaches of This Policy
Any violation of this policy may lead to disciplinary action, including termination of employment or contracts for misconduct or gross misconduct. We may also sever relationships with contractors, suppliers, or any individuals or organizations working on our behalf if they are found to be in breach of this policy.
Responsibility for This Policy
The implementation and enforcement of this policy are the responsibility of senior management. All employees and business partners must be diligent in adhering to this policy and ensuring that modern slavery is not part of our business activities or supply chains.
Steps for the Prevention of Modern Slavery
We maintain a strong commitment to preventing modern slavery through the following policies:
- Third Party Due Diligence Policy
- Whistleblowing Policy
- Financial Crime Policy
- Health and Safety Policy
These policies guide our actions and reinforce our commitment to eradicating modern slavery in any form.