Modern Slavery Policy

Policy Statement  

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery,  servitude, child labour, 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 implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chain.  

We are also committed to ensuring there is transparency in our own business and in our approach to tackling  modern slavery throughout our supply chain. We expect the same high standards from all our contractors,  suppliers and other business partners. We require that our contractors, suppliers and employees are  specifically prohibited against the use of forced, compulsory or trafficked labour, child labour or anyone held in  slavery or servitude. Further conduct such as withholding worker identity or immigration documents, using recruiters that do not comply with local labour laws of the country in which the recruiting takes place or charging workers recruitment fees be prohibited and we expect that our suppliers will hold their own  suppliers to the same high standards.  

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, 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 the Policy  

The Finance Department has overall responsibility for ensuring this policy complies with our legal and ethical  obligations including 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. Management at all levels are responsible for ensuring those reporting to them understand and  comply with this policy and are given any required training.  

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 chain 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.  

You must notify your manager or the Finance Department as soon as possible if you believe or suspect that a  conflict with this policy has occurred or may occur in the future.  You are encouraged to raise concerns about any issue of suspicion of modern slavery in any parts of our  business or the supply chains of any supplier tier at the earliest possible stage.

If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your  manager or report it to the Finance Department.  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 chain constitutes any of the various forms of modern slavery, raise it  with your manager or the Finance Department.  

We aim to encourage openness and will support anyone who raises genuine concerns in good faith 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 good faith their suspicion that modern slavery of whatever form is or may  be taking place in any part of our own business or in any part of our supply chain. If you believe that you have  suffered any such treatment, you should inform your manager immediately.  

Communication and Awareness of Policy  

This policy and our zero-tolerance approach to modern slavery should be communicated to all at the outset of our relationship with them and will form part of our terms and conditions with suppliers on purchase order.  

Breaches of this 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.