Modern Slavery & Human Trafficking Policy

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

he companies strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We 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. We expect that our suppliers will hold their own suppliers to the same high standards.

Definitions:

  • Modern Slavery and Human Trafficking 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.

We are a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

  • 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-based approach 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.

This policy is regularly reviewed by Senior Management with the involvement of relevant stakeholders.