Modern Slavery 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 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.

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 the same high standards from all of our contractors, suppliers and other business partners, and where appropriate as part of our contracting processes, we will seek to 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.

This policy applies to all persons working for us or on our behalf in any capacity, including employees and consultants at all levels

1. Compliance with the 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.  All staff are required to avoid any activity that might lead to, or suggest, a breach of this policy. 

All staff must make a notification as soon as possible if they believe or suspect that a conflict with this policy has occurred, or may occur in the future.  

If any member of staff is 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, they should raise the issue with us.

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 any member of staff believes that they have suffered any such treatment, should inform us immediately.

2. Communication and awareness of this policy 

All new members of staff will be made aware of this policy on induction and will be provided such further information as they require in order to understand their obligations under the terms of this policy.  Where appropriate, our zero-tolerance approach to modern slavery should be communicated to relevant suppliers, contractors and other business partners. 

3. Breaches of this policy 

Any person 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.