Modern slavery is a crime and a violation of fundamental human rights. All types of modern slavery have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We are committed to acting ethically and with integrity in all our business dealings and relationships and to ensure modern slavery is not taking place anywhere in our own business, or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our business relationships, consistent with our obligations under the Modern Slavery Act 2015. As part of this process, we have undertaken a review of our supply chain to identify and assess potential risk areas and maintain a register detailing the same. We maintain a policy of employing our own staff (rather than using staff supplied by third party agencies) but we do have personnel working on behalf of suppliers working on our premises. Where we utilise people via suppliers working on our site, we will always:
Request (and keep on the supplier file) a written response from the supplier confirming their awareness and commitment to their obligations under the Modern Slavery Act 2015.
When we feel it necessary, interview personnel working for suppliers on our site against the checklist of questions contained in Appendix A.
The results of these surveys will be drawn to the attention of the supplier and to the appropriate authorities in respect of any apparent breach of the obligations of the Act.
We expect high standards from all of our subcontractors, suppliers and other business partners and we will make this a contractual term in our agreements with significant suppliers wherever possible.
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, interns, 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 at any time.
RESPONSIBILITY FOR THIS POLICY
The Directors of the firm have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all of our people comply with it.
The Management team have primary and day-to-day responsibility for implementing this policy, and our HR advisors provide assistance with reviewing the risk profile of our supply chain to ensure that any procedures implemented are effective in countering modern slavery.
COMPLIANCE WITH THIS 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 chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
Although you should report any concerns regarding modern slavery and/or human trafficking in any parts of our business or supply chains, you are also encouraged to discuss a specific matter (or our policy or relevant legislation) with any member of the management team.
If you are in any doubt about whether a particular act or working conditions in any of our business relationships may contravene any aspect of this policy then err on the side of caution and report it to a member of the management department.
We encourage openness and will support anyone who raises genuine concerns in good faith, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their knowledge, or suspicion, that modern slavery is taking place in any part of our business or in any of our supply chains.
COMMUNICATION AND AWARENESS OF THIS POLICY
Our zero-tolerance approach to modern slavery is communicated to all significant 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 who breaches this policy could face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.