Modern Slavery Policy

1. Policy Statement


This policy applies to all persons working for the Company or on our behalf in any capacity, including employees or workers at all levels, directors, officers, agency workers, seconded workers, volunteers,
agents, contractors and suppliers.

The Company strictly prohibits the use of modern slavery and human trafficking in our operations and
supply chain. The Company have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. The Company expect that our suppliers will hold their own suppliers to the same high standards.

2. Terminology

Modern Slavery and Human Trafficking

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded
and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the
travel of another person with a view to that person being exploited. Modern slavery is a crime and a
violation of fundamental human rights.

3. Commitments

The Company shall be a company that expects everyone working with us or on our behalf to support and
uphold the following measures to safeguard against modern slavery: The Company have a zero-tolerance approach to modern slavery in our organisation and our supply chains.

  • The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
  • The Company are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
  • The Company take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach, we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.
  • Consistent with our risk-based approach we may require:
    • Employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct.
    • Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code
  • As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.
  • If we find that other individuals or organisations working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships

4. Reporting a Concern

You are responsible for observing and upholding our position on anti slavery and human trafficking and to raise any suspsicions or concerns to the Company.

You must notify your line manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. For example, if a third party, client or potential client may be involved in activities that could fall within the definitions of modern salvery and / or human trafficking. Any breach of this policy will normally be a disciplinary offence, which could result in your dismissal for gross misconduct.

You are encouraged to raise concerns about any issue or suspicion at the earliest possible stage. If you are unsure about an activity and whether it meets the definition or if you have any other queries, these should be raised with your line manager. Concerns should be reported by following the procedure set out in the Company’s Whistleblowing Policy.

It is important that you notify your line manager as soon as possible if you have any suspicions regarding modern slavery and / or human trafficking or believe that you are a victim of another form of unlawful activity.

5. Confidential and Safe Reporting Procedures

Those who refuse to engage in activities they are concerned involve modern slavery and / or human trafficking, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy.

The Company is committed to ensuring that no one suffers any detrimental treatment as a result of raising any concerns under this policy. If you believe that you have suffered any such treatment, you should inform your line manager immediately. If the matter is not remedied, then you should raise it formally using our Grievance Procedure. Where the Grievance procedure is not applicable you should raise a formal complaint.

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