Anti-Slavery Policy
- Introduction
1.1. The company has a zero-tolerance approach to any form of modern slavery or human
trafficking in our operations and supply chains. We are committed to acting ethically and
with integrity in our business activities and to implementing systems to combat modern
slavery in compliance with the Modern Slavery Act 2015.
1.2. Under the Modern Slavery Act 2015, modern slavery encompasses:
Slavery, servitude, and forced or compulsory labour
Human trafficking
Exploitation, including sexual exploitation
Forced marriage
1.3. We will ensure transparency and fairness in our employment practices. Our recruitment processes will be ethical and compliant with applicable laws, including the Modern Slavery Act 2015.
1.4. We will implement and maintain effective systems and controls to ensure modern slavery is not taking place anywhere in our business or supply chains. - Due Diligence Processes
2.1. We undertake due diligence when considering taking on new suppliers, and regularly review our existing suppliers. Our due diligence includes:
Mapping the supply chain to assess particular product or geographical risks
Evaluating modern slavery and human trafficking risks of each new supplier
Conducting supplier audits or assessments
Taking steps to improve substandard suppliers’ practices - Training and Awareness
3.1. Employees will receive training to:
Understand the requirements of the Modern Slavery Act 2015
Recognize signs of potential modern slavery or human trafficking
Know how to report suspicions of modern slavery
Understand the company’s procedures for responding to reports
3.2. Through engagement, collaboration and training, we will work to uphold human rights and fair labour practices throughout our organisation and business relationships. - Employee Rights and Protections
4.1. For our employees, we commit to:
a) Pay our employees regularly and in accordance with their terms and conditions, providing a written summary of pay and deductions on each occasion
b) Provide a full formal grievance framework as detailed in this Handbook
c) Support whistleblowing in relation to modern slavery concerns
d) Never hinder any employee’s freedom of movement or their opportunity to seek employment elsewhere
e) Respect employees’ right to join or not join a trade union at their complete discretion
f) Never withhold identity documents, wages, or other benefits
g) Never require employees to pay recruitment fees or costs - Reporting Concerns
5.1. All employees, contractors and other business partners are encouraged to report any concerns about modern slavery in any part of our business or supply chains at the earliest possible stage.
5.2. Reports can be made:
To line managers
Through our confidential whistleblowing procedure
Directly to the Modern Slavery Helpline (0800 0121 700)
5.3. We commit to investigating and addressing all reported concerns promptly and thoroughly. - Supply Chain Transparency
6.1. We require all suppliers to comply with:
The Modern Slavery Act 2015
Our supplier code of conduct
All applicable local and international laws
6.2. We will terminate relationships with suppliers who fail to demonstrate commitment to combating modern slavery.
Date: 22nd January 2025
Version: 2.03