MODERN SLAVERY ACT
1. POLICY STATEMENT
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 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.
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.
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
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,
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 adequate and regular training on it and the issue of modern
slavery in supply chains.
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 compliance
manager.
3. 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 required to avoid
any activity that might lead to, or suggest, a breach of this policy.
You must notify the Managing Director 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 or suspicion of modern slavery in any parts of
our business or supply chains, at 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 the
compliance manager as soon as possible.
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 the Operative Care Team in the first instance, who will report,
investigate and escalate if necessary.
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 Managing Director immediately. If the matter is not remedied, and
you are an employee, you should raise it formally using our Grievance procedure.
4. COMMUNICATION AND AWARENESS OF THIS POLICY
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.
Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors
and business partners at the outset of our business relationship with them and reinforced as
appropriate thereafter.
5. 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.