Modern Slavery Policy Statement
MODERN SLAVERY POLICY STATEMENT
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 in order to exploit
them for personal or commercial gain. We have a zero-tolerance approach to modern
slavery and we are committed to acting ethically and with integrity in all our business
dealings and relationships and to implement and enforce effective systems and controls to
ensure modern slavery is not taking place anywhere inour own business or our supply
We are also committed to ensuring there is transparency in our own business and in our
approach totackling modern slavery throughout our supply chain. We expect the same high
standards from all ofour contractors, suppliers and other business partners. 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
employeesat 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 atany time.
RESPONSIBILITY FOR THE POLICY
The Managing Director has overall responsibility for ensuring this policy complies with our
legal and ethical obligations, and that all those under our control comply with it
The Managing Director has primary and day-to-day responsibility for implementing this
policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing
internalcontrol systems and procedures to ensure they are effective in countering modern
Employees at all levels are responsible for ensuring those reporting to them
understand andcomply with this policy and are given any required training.
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 avoidany activity that might lead to, or suggest, a breach of this policy.
You must notify the Managing Director as soon as possible if you believe orsuspect 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 ofour business or the supply chains of any supplier tier at the earliest possible
If you believe or suspect a breach of this policy has occurred or that it may occur you
must notify the Managing Director or report it in accordance with our Whistleblowing
Policy as soon as possible.
If you are unsure about whether a particular act, the treatment of workers more generally,
or theirworking conditions within any tier of our supply chain constitutes any of the various
forms of modern slavery, raise it with the Managing Director.
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 suffersany 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. If you believe that you have suffered any
such treatment, you should inform your manager immediately.
COMMUNICATION AND AWARENESS OF POLICY
Training on this policy, and on the risk our business faces from modern slavery in its supply
chain willbe given where needed.
Our zero-tolerance approach to modern slavery must be 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
Any employee / consultant who breaches this policy will face disciplinary action, which
could result in dismissalfor misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our
behalf if they breach this policy.