Modern Slavery Act 2015

Slavery and Human Trafficking Statement

  1. POLICY STATEMENT
    1. Modern slavery is a crime and an abuse of human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the removal 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.
    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. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
    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.
    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
    1. The HR department has 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. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
    3. You are invited 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 Hr department.
  1. COMPLIANCE WITH THE POLICY
    1. You must ensure that you read, understand and comply with this policy.
    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. You must notify your manager as soon as possible if you believe or suspect that a breach of this policy has occurred, or may occur in the future or report it in accordance with our Whistleblowing policy.
    4. 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 anyone of senior level.
    5. 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 of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the 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 in our handbook and HR document library.
  2. COMMUNICATION AND AWARENESS OF THIS POLICY
    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 regular training will be provided as necessary.
  3. BREACHES OF THIS POLICY
    1. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
    2. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

This page was last updated October 2018 as was correct at time of publishing. You can download a PDF copy of this document by clicking the download button below.

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