Anti Slavery & Human Trafficking Policy

Policy 22- Anti Slavery & Human Trafficking 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 to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships. We are dedicated to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or in any of our supply chains.

We are also committed to ensuring 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 our contractors, suppliers, and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory, or trafficked labor, or anyone held in slavery or servitude, whether adults or children. We expect our suppliers to hold their own suppliers to the same high standards.

Definitions:

Modern Slavery-

Modern slavery encompasses slavery, servitude, forced and compulsory labour, and human trafficking.

Risk Assessment: We conduct regular risk assessments to identify and address potential areas of risk within our operations and supply chains. This aids in developing targeted strategies to prevent and mitigate the risk of modern slavery.

Supply Chain Transparency: We are committed to supply chain transparency. This involves thorough supply chain mapping and due diligence to understand and assess the risks associated with each tier of the supply chain.

Training and Awareness: Training on this policy, as well as 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. Regular training sessions will be provided to ensure ongoing awareness and vigilance among employees.

Reporting Mechanism: If you believe or suspect that a conflict with this policy has occurred or may occur in the future, notify your manager or the compliance manager as soon as possible. We encourage openness and will support anyone who raises genuine concerns under this policy. The reporting mechanism is detailed in our Whistleblowing Policy.

External Communication: We communicate our commitment to anti-slavery efforts to external stakeholders, customers, and the public, demonstrating our dedication to ethical business practices.

Monitoring and Evaluation: We regularly monitor and evaluate the effectiveness of this policy. Periodic assessments help identify areas for improvement and ensure continuous compliance.

International Operations: This policy applies to all persons working for us or on our behalf. We recognise the importance of considering legal requirements and cultural contexts in different regions.

Responsibility for the Statement: 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. The compliance manager has primary and day-to-day responsibility for implementing this policy.

Compliance With The 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 encouraged 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 compliance manager. This policy does not form part of any employee’s contract of employment, and we may amend it at any time.

Breaches of The Policy: Any employee who breaches this policy will 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.

Robert Doherty

Managing Director

v3.1 16/04/2024