Slavery and human trafficking have many different forms, these include forced labour, child labour, exploitation, being sold or treated as a commodity and having restrictions on freedom of movement etc.
The Group has 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 developing and implementing effective management systems and controls that ensure that nowhere in our business or supply chain is involved with Modern Slavery.
By ensuring that our business is transparent, we will ensure we will comply with the disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include prohibitions against the use of staff sourced from forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect that our Supply Chain will also hold their own Supply Chain to the same high standards.
This policy applies to all those employed or working on behalf of the Group, in any capacity. This includes but does not limit the policy applicability to; employees, agency workers, temporary staff, contractors, external consultants, third-party representatives and business partners. This policy does not form part of any employee’s contract of employment and we reserve the right to amend it any time.
The Group’s Executive Team 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 Head of ESG and Improvement has primary responsibility for implementing this policy. This will include monitoring its use and effectiveness and auditing internal control systems and procedures as part of our Integrated Management System to ensure they are effective in countering Modern Slavery.
Management at all levels are 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 within supply chains.
As with all of the Group’s policies and procedures, employees are invited to comment on this policy and suggest ways in which it might be improved, this can be done through the Employee’s line manager.
Individuals and/or Organisations working for or on behalf of the Group must ensure that they read, understand and comply with this policy.
The prevention, detection and reporting of Modern Slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. They are required to avoid any activity that might lead to, or suggest, a breach of this policy.
If anyone believes or suspects that a conflict with this policy or possible breach has occurred, or may occur in the future, it must be reported to the relevant manager as soon as possible. This can be done in accordance with the Group’s Whistleblowing Policy.
Individuals and/or Organisations working for or on behalf of the Group are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at the earliest possible stage.
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, raise it immediately with the relevant manager.
The Group will ensure compliance by identifying and mitigating risk in the following ways: –
Any employee found in breach of this policy will face disciplinary action, this could result in dismissal in accordance with the Group’s HR Policies. The Group may terminate our relationship with other individuals, contractors, agencies or other suppliers working with the Group if they are found in breach of this policy.
The Group will regularly review the effectiveness of the policies and procedures on the basis of reports received, changes of regulation and legislation, changes of working practices and in any event at intervals not exceeding 12 months.
Our Policy is communicated to all employees and is made available to our supply chain and other interested parties to inform them of our zero-tolerance approach to modern slavery and to promote wider adoption of responsible practices.
This policy is in accordance with Section 54 of the Modern Slavery Act 2015 and constitutes our business’s slavery and human trafficking statement for the year ended 31st December 2020.
Tim Cockayne, CEO
15 January 2021