Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or any of our supply chains.
We are also committed to ensuring transparency in our business and our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all our contractors, suppliers, and other business partners. As part of our contracting processes, we include specific prohibitions against forced, compulsory or trafficked labour or anyone held in slavery or servitude, whether adults or children. We expect our suppliers to have their suppliers to the same high standards. Forced labour and discrimination of ethnoreligious minorities, such as in Xinjiang Uyghur Autonomous Region (XUAR), is strictly prohibited.
This policy applies to all persons working for us or on our behalf, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, and third-party representatives and business partners.
This policy does not form part of any employee’s employment contract, and we may amend it at any time.
Responsibility for the Policy
The board of directors is responsible for ensuring that this policy complies with our legal and ethical obligations and that all those under our control comply.
The managing director is primarily responsible 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 effectively counter modern slavery.
Management at all levels is responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions, and queries are encouraged and should be addressed to the managing director.
Compliance with the Policy
You must ensure that you read, understand, and comply with this policy.
You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
If you believe or suspect a breach of this policy has occurred or may occur, you must notify your manager as soon as possible.
If you are unsure whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they are mistaken. We are committed to ensuring no one suffers any detrimental treatment due to reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our business or supply chains. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern.
If you believe you have suffered any such treatment, you should inform the compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.
Communication and Awareness of this Policy
Training on this policy, and the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
Our zero-tolerance approach to modern slavery in our business and supply chains must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship and reinforced as appropriate.
Breaches of this Policy
Any employee who breaches this policy will face disciplinary action, resulting in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.