Anti Human Trafficking and Slavery Policy

1. Policy statement

1.1. Anti-slavery policy

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 for their own personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically with integrity in all our business dealings and relationships. To ensure that modern slavery is not taking place anywhere in our own business or in any of our supply chains we will implement effective systems and controls.

1.2. Anti-slavery standards

We are committed to ensuring there is transparency in our own business and in 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 of our contractors, suppliers and other business partners, and 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.

2. About this policy

2.1. The purpose of this policy is to:

(a) Modern slavery set out our responsibilities, and of those working for and on our behalf, in observing and upholding our position on modern slavery and human trafficking; and

(b) Identify and report concerns

Provide information to those working for and on our behalf on how to identify and report concerns regarding modern slavery and human trafficking.

2.2. Applicable persons

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

2.3. Employee policy

This policy does not form part of any employee's contract of employment, and we may amend it at any time.

3. Responsibility for the policy

3.1. Overall responsibility

The board of directors or individual has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under their control comply with it.

3.2. Compliance manager

The Head of Operations is 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 are effective in countering modern slavery.

3.3. Training and compliance

Management at all levels are responsible for ensuring that those reporting to them understand and comply with this policy and receive adequate and regular training on the issue of modern slavery in supply chains.

3.4. Feedback encouraged

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 Head of Operations.

4. Your responsibilities and how to raise a concern

4.1. Comply with policy

You must ensure that you read, understand and comply with this policy.

4.2. Anti-slavery policy

It is the responsibility of all those working for us or under our control to avoid any activity that might lead to, or suggest, a breach of this policy. You are required to report any suspected breaches of this policy.

4.3. Breach of policy

You must notify Head of Operations as soon as possible if you believe or suspect that a breach of this policy has occurred, or may occur in the future.

4.4. Modern slavery

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business or supply chains, at the earliest possible stage.

4.5. Notify breach

If you believe or suspect that a breach of this policy has occurred or that it may occur you must notify the Head of Operations as soon as possible.

4.6. Raise concerns

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 chains constitutes any form of modern slavery, raise it with your manager or Head of Operations.

4.7. Protected reporting

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 suffers any detrimental treatment as a result of raising a concern.

Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that 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, which can be found in the company shared drive.

5. Training and communication

5.1. Employee training

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.

5.2. Communication of commitment

Our zero-tolerance approach to modern slavery in our business and supply chains must be communicated at the outset of our business relationship with them, and reinforced as appropriate on an ongoing basis.

6. Breaches of this policy

6.1. Disciplinary action

Any employee who breaches this policy will face disciplinary action, which may result in dismissal for misconduct or gross misconduct.

6.2. Termination

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.