Introduction

This document is a statement of the Company’s Modern Slavery Policy. The details are below. This policy is not part of your employment contract and it is not legally binding except where it is a statement of the law. You must be aware of this policy and procedure and apply it accordingly; failure to do so may result in disciplinary action being taken against you. You should consult your manager if there is anything that is not clear to you or if you are unsure about any aspect of this policy.

Policy Statement

Modern slavery is a criminal offence under the Modern Slavery Act 2015. Modern slavery can occur in various forms, including servitude, forced or 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. This document sets out the Company’s policy with the aim of the prevention of opportunities for modern slavery to occur within its business or supply chain. This policy’s use of the term “modern slavery” has the meaning given in the Modern Slavery Act.

The Company acknowledges its responsibilities with regard to ensuring that its operations do not involve any modern slavery and commits to complying with the requirements of the Modern Slavery Act 2015.

This policy applies to all persons who work the Company directly or on our behalf in any capacity, including all employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, work experience workers, contractors, external consultants, third party representatives and business partners.

The Company has a zero-tolerance of modern slavery in any form. The Company is committed to acting ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its own business or its suppliers’ businesses.

The Company is committed to ensuring there is transparency in its own business and in its approach to tackling modern slavery throughout its supply chains. The Company expects that all of its contractors, suppliers and other business partners will uphold and apply the same high standards as the Company applies. To this end the Company will implement and maintain contracting processes to include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. It will require all suppliers to hold their own suppliers to the same high standards as those that we expect and require of our suppliers. The Company will communicate this policy to all its suppliers and stakeholders at the commencement of any association with that supplier or stakeholder and ensure that all those associated with the Company will not, under any circumstances, tolerate modern slavery in its own organisation or any organisation or individual with which it is associated. This policy and its contents will be re-communicated to those individuals and organisations from time to time thereafter.

Although the Company takes steps to implement policies and practices to ensure that modern slavery is not taking place in its own operations, it recognises that it does not have control on those who run or work in its supply chain. However, to ensure the Company’s compliance with this policy and its statutory requirements and responsibilities the Company will implement the following actions:

• Undertake risk assessments to determine which parts of the Company’s business is at risk of modern slavery and address those areas of the business as a matter of urgency;
• Undertake risk assessments to determine which suppliers’ businesses are at risk of modern slavery and positively engage with those suppliers that are identified to be at risk to gain an understanding of the measures taken by them to ensure modern slavery is not occurring in their businesses and their supply chain and to ensure compliance with the Company’s requirements;
• Introduce supplier pre-screening as part of the Company’s buying and tender processes;
• Introduce contractual provisions for our suppliers to confirm their adherence to this policy, to accept our right to audit their activities and (where practicable) relationships, both routinely and at times of reasonable suspicion.
• The Company will terminate any supplier contract where the Company suspects that the supplier is involved in modern slavery and fails to take the required actions to cease involvement in modern slavery within the required timeframe.
• Undertake training of the Company’s employees in modern slavery.

RESPONSIBILITY FOR THIS POLICY

The Company’s Directors have ultimate responsibility for the prevention of modern slavery in the Company and its supply chain and for ensuring that this policy and its implementation comply with its legal and ethical obligations.

Directors and managers at all levels in the Company 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.

HR Manager is the Company’s appointed Slavery Compliance Officer who has personal responsibility to the Directors on a day to day basis for undertaking the required actions for the implementation of this policy and the person to whom all concerns should be formally addressed either internally or by anyone outside the Company.

All employees are encouraged to raise any concerns they may have about suspected modern slavery associated with the Company’s operations or those of our suppliers by immediately informing their line manager or HR Manager of their concerns.

The Company encourages openness and will support anyone who raises genuine

concerns in good faith under this policy, even if those concerns ultimately turn out to be mistaken. The Company is committed to ensuring no one suffers any detrimental treatment, such as dismissal, disciplinary action, threats or other unfavourable treatment, as a result of reporting in good faith their suspicion that modern slavery of whatever form is or could be taking place in any part of the Company or in any of the Company’s supply chains.

Any concern that an individual raises with the Company about modern slavery will be taken seriously. It will be investigated and, where the Company has a reasonable belief that modern slavery is taking place, addressed with urgency. The individual who raises the concern will be informed of the outcome of the investigation. Wherever possible, the Company would prefer that the individual enables their name to be associated with such a concern reported to the Company. However, an individual may express a concern anonymously, although this may render any investigation less effective.

If, as a result of an investigation, the Company has a reasonable belief that an employee has been knowingly involved with or associated with modern slavery, the employee will be subject to the Company’s Disciplinary Policy which could ultimately lead to dismissal with or without notice.

Where a concern is raised regarding a supplier and the Company has reasonable belief that modern slavery is taking place in that supplier, it will work with the supplier to prepare and ensure implementation of an action plan to resolve the matter within an agreed time frame. If the supplier fails to address the concern, implement an action plan or meet an agreed time frame, the Company reserves the right to terminate any relationship with that supplier.

Data protection

To operate and administrate the Modern Slavery Policy, the Company needs to collect and process personal data. This personal data will be processed in accordance with the Company’s Data Protection Policy and Employee Privacy Notice. Where it is necessary for the Company to collect and process information, which is called Special Categories of personal data, such personal data will be collected in accordance with the Company’s Data Protection Policy and Employee Privacy Notice related to the processing of special categories of personal data. The Company has a legitimate and may have a legal interest in processing this personal data to ensure that the Modern Slavery Policy is complied with and any process associated with it correctly managed.

All personal data collected and processed by the Company is held securely and only accessed or disclosed to those individuals who require such information for the purposes for which it was collected. Any inappropriate access or disclosure of personal data is treated as a data breach. You should immediately report any such inappropriate access or disclosure to the person responsible for data protection as shown in, and in accordance with, the Company’s Data Protection Policy. Such a breach will be investigated and dealt with under the Company’s Disciplinary Policy and Procedure.

This document is a statement of the relevant law where appropriate together with the Company’s policies on the subject. The Company reserves the right to amend any non-statutory parts of this policy.

This document was current as at 21/10/2021. New Employment legislation and case law means that this document will become out of date and will need reviewing and amending, preferably every 12 months.