Modern Slavery Policy

This policy applies to anyone working for our companies. This includes employees, workers, contractors, volunteers, interns, and apprentices. The policy also relates to job applicants and is relevant to all stages of the employment relationship.

Introduction

Modern slavery is a complex and multi-faceted crime and tackling it requires all of us to play a part. You may think this whole subject is irrelevant to us, but it is not. At a very basic level, of course preventing exploitation and human trafficking, and protecting our workforce and reputation makes good business sense.

The Modern Slavery Act 2015 covers four activities:

• Slavery: Exercising powers of ownership over a person.
• Servitude: The obligation to provide services is imposed by the use of coercion.
• Forced or compulsory labour: Work or services are exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily.
• Human Trafficking: Arranging or facilitating the travel of another person with a view to their exploitation.

The Modern Slavery Act 2015 recognises the important part organisations can and should play in tackling slavery. With this in mind, we need to pay particularly close attention to:

• Our supply chain
• Any outsourced activities, particularly to jurisdictions that may not have adequate safeguards

Responsibilities

Our companies will:

• Maintain clear policies and procedures preventing exploitation and human trafficking and protecting our workforce and reputation.
• Be clear about our recruitment policy.
• Check our supply chains.
• Lead by example by making appropriate checks on all employees, recruitment agencies, suppliers, etc., to ensure we know who is working for us.
• Ensure we have an open and transparent grievance process for all employees.
• Seek to raise awareness to promote the welfare of our colleagues.
• Make a clear statement that we take our responsibilities to our employees and clients seriously.

Managers will:

• Listen and be approachable to colleagues.
• Respond appropriately to indicators of exploitation.
• Remain alert to indicators of slavery.
• Raise awareness among colleagues through discussions and training.
• Use experience and professional judgement to gauge situations.

Colleagues will:

• Keep eyes and ears open—report any suspicions of exploitation.
• Follow the reporting procedure if they suspect exploitation or ill-treatment.
• Provide feedback on ways to improve anti-slavery measures.

The Risks

The principal areas of risk we face include:

• Supply chains
• Recruitment through agencies
• General recruitment

Supply Chains

We will check supply chains to ensure the potential for slavery and human trafficking is significantly reduced. All standard supplier contracts will contain an anti-slavery clause prohibiting exploitation.

Using Agencies

We ensure the potential for slavery and human trafficking is reduced through:

• Conducting background checks
• Investigating reputation
• Ensuring appropriate documentation (e.g., work visas)
• Regular reviews of approved recruitment agencies

Identifying Slavery

Key indicators of trafficking or slavery include:

• Lack of possession of personal documents
• Being instructed or coached by someone else
• Limited social interaction

Reporting Slavery

If you suspect someone is at risk of exploitation, report your concerns to HR or a manager. If immediate danger is suspected, dial 999.

Monitoring Our Procedures

We will review our Anti-slavery Policy annually and provide updates on changes.

Our Anti-Slavery Statement

We have a zero-tolerance approach to modern slavery. We commit to acting ethically, ensuring transparency, and implementing controls to prevent exploitation in all business dealings.