Modern Slavery Policy Statement

Modern slavery is a crime and a violation of fundamental human rights. Its various forms – slavery, servitude, forced and compulsory labour and human trafficking – have in common the deprivation of a person’s liberty by another for the purpose of exploiting them for personal or commercial gain.

We have a zero-tolerance approach to modern slavery and are committed to: –

• acting ethically and with integrity in all our business dealings and relationships with our suppliers and customers.
• ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout supply chains.

We facilitate and conduct Ethical Audits of our suppliers as a standard business practice and share the findings of these Audits with our customers.

We encourage everyone to adopt our standards. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude and we expect that our suppliers will hold their own suppliers to the same high standards.

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, agents, contractors, external consultants, third-party representatives, and business partners. This policy does not form part of any employee’s contract of employment and we may amend it at any time.

RESPONSIBILITY FOR THE POLICY

The Company Directors have overall responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

COMPLIANCE WITH THE POLICY

You must ensure that you read, understand, and comply with this policy. The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control.

You are required to avoid any activity that might lead to, or suggest, a breach of this policy and must notify us as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.

You are encouraged to raise concerns about any issue of suspicion of modern slavery in any parts of our supply chains or any supplier tier at the earliest possible stage. If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify us as soon as possible. If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chain constitutes any of the various forms of modern slavery, please discuss this with us.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any part of our supply chain.

COMMUNICATION AND AWARENESS OF POLICY

Training on this policy, and on the risk our business faces from modern slavery in its supply chain will be given where needed. Our zero-tolerance approach to modern slavery is communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

BREACHES OF THIS POLICY

We may terminate our relationship with any organisations working on our behalf if they breach this policy. We may provide support to remedy and improve working practices where a breach of this policy is determined.