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Anti-slavery and human trafficking policy

1     Policy statement

1.1   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 in order to exploit them for personal or commercial gain. We have 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 to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

1.2  We are also 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 high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we notify all members of our supply chain of the specific prohibitions against the use of forced, compulsory or trafficked labourand we expect that our suppliers will hold their own suppliers to the same standards. Our contractual documentation will include these   specific provisions.

1.3  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.

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

2     Responsibility for the policy

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

2.2  The compliance managers (currently Jason Curtis, Legal Director and Company Secretary and Richard Spychalski, Operations Director) have primary and day-to-day responsibility 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.

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

3     Compliance with the policy

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

3.2  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.

3.3  You must notify a compliance manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.

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

3.5  If you believe or suspect a breach of this policy has occurred or that it may occur you must report it in accordance with our Whistleblowing Policy as soon as possible Any subsequent investigation will be handled in accordance with the Whistleblowing Policy.   

3.6  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 of the various forms of modern slavery, raise it with your manager or a compliance manager.

3.7  We aim to encourage openness and will support anyone who raises genuine concerns 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 reporting in their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. It also includes being put under any pressure not to raise a concern under this policy.  If you believe that you have suffered any detrimental treatment, you should inform a 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 on our intranet.

4     Communication and awareness of this policy

4.1  Training on this policy, and on 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 updated training will be provided as necessary.

4.2  Our zero-tolerance approach to modern slavery should be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

5     Breaches of this policy

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

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

 

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