Anti-Slavery and Anti-Trafficking Policy

This policy aligns with our broader sustainability goals by promoting responsible business practices that respect human rights and contribute to social equity.

1. INTRODUCTION

The Company has implemented an Anti-slavery and anti-trafficking policy reflecting its commitment to combatting slavery and human trafficking and to acting with integrity in all its dealings, relationships, and supply chains. The policy outlines how the Company’s various procurement, policies and procedures ensure compliance with its policy commitment.

2. POLICY

 2.1   Modern slavery encompasses slavery, forced and compulsory labour, and human trafficking whereby individuals are deprived of their freedom and are exploited for commercial or personal gain as defined in the Modern Slavery Act 2015.

2.2   The Modern Slavery Act 2015 covers four activities:

3. SCOPE

3.1   The Company, our senior leaders, managers, and colleagues have a responsibility to ensure all our fellow workers are safeguarded, treated fairly and with dignity. Everyone must observe this policy and be aware that turning a blind eye is unacceptable.

3.2   The Company is committed to combatting slavery and human trafficking and to acting with integrity in all its dealings, relationships, and supply chains. It expects the same high standards from all its staff, suppliers, contractors, and those with whom it does business. This policy applies to all employees, workers, consultants, and other persons doing business with the Company including all its contractors, and suppliers. It does not, however, apply to the Company’s customers.

3.3   The Company acknowledges the risk that a supply chain may involve the use of a hidden or unknown subcontractor reliant on forced labour. Although the Company considers the risk of modern slavery to be low due to the nature of its supply chains, it takes its responsibilities to combat modern slavery seriously as demonstrated by its promotion and adoption of the following policy measures:

 The prevention, detection, and reporting of modern slavery in any part of its business or supply chains is the responsibility of all those working for the Company or under its control.

• Appropriate due diligence processes must be carried out in relation to modern slavery which may include considering human rights in a sector or country, the type of sector in which a service provider operates, the countries from which services are provided, the nature of relationships with suppliers, and the complexity of supply chain(s).
• All supply chain lines need to be continually risk assessed and managed in relation to modern slavery and any high-risk suppliers audited. The Company’s standard procurement and contract procedures and documentation address anti-slavery and anti-trafficking and checks that all potential new suppliers and existing suppliers have in place Anti-slavery policy’s which are compliant with the Modern Slavery Act 2015 as part of due diligence processes.
• Under the supplier approval process the Company’s CEO and VP’s review all new suppliers, any changes to existing suppliers and re-contract negotiations taking this into account.
• The Company encourages anyone to raise any concerns about modern slavery, using its whistleblowing policy if necessary, and will support anyone who acts in good faith.
• The Company will continue to develop its commitment to combat modern slavery and human trafficking and will outline such activities within its anti-slavery and anti-trafficking policy.
• Effective from the date of publication of this policy, all our standard supplier contracts will include an anti-slavery clause. This clause prohibits suppliers and their employees from participating in any form of slavery or human trafficking.

4. GENERAL RECRUITMENT

 4.1 The Company is committed to combating modern slavery through robust recruitment practices which include:

• Ensuring all staff have a written contract of employment.
• Carrying out right to work checks to ensure all staff are legally able to work in the UK.
• Providing information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to.

5. ALL EMPLOYEES

5.1   If, through our recruitment process, you suspect someone is being exploited you must report this immediately to the HR Director who will follow reporting procedures.

5.2   Any breaches of this policy may result in the Company taking disciplinary action against individual(s) and/or terminating its relationship with any organisation or supplier.