1. Policy Statement
Modern slavery is a crime and a violation of fundamental human rights. It includes slavery, servitude, forced and compulsory labour, and human trafficking — all of which involve the deprivation of a person’s liberty for personal or commercial exploitation.
We adopt a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business relationships and to implementing effective systems and controls to ensure that modern slavery is not taking place within our organisation or across our supply chains.
We expect the same high standards from all our contractors, suppliers, and business partners. As part of our procurement and 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. We require our supply chain partners to uphold the same ethical standards.
This policy applies to all individuals working for or on our behalf in any capacity, including directors, employees at all levels, agency workers, contractors, consultants, volunteers, apprentices, interns, and third-party business partners.
2. Responsibility for the Policy
Our directors have overall responsibility for ensuring that this policy complies with relevant legislation, including the Modern Slavery Act 2015, and that all individuals under our control understand and comply with it.
Managers at all levels are responsible for ensuring that those reporting to them are made aware of this policy and are provided with adequate training and support to understand the risks of modern slavery, particularly in relation to supply chain management and procurement.
3. Risk Management and Due Diligence
We undertake due diligence and risk assessments across our operations and supply chains.
Steps taken to manage modern slavery risks include:
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- Conducting supplier assessments and checks before engagement
- Including anti-slavery obligations in contracts and service agreements
- Monitoring supplier compliance and conducting audits where appropriate
- Prioritising due diligence for suppliers operating in high-risk sectors or jurisdictions
- Providing modern slavery awareness training for relevant employees
4. Reporting Concerns
Anyone working for or with us is encouraged to report any concerns regarding modern slavery or human trafficking. Concerns may be raised through:
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- A line manager or senior leader
- Our designated whistleblowing channels
- The Human Resources or Compliance teams
All reports will be treated confidentially, taken seriously, and investigated promptly and thoroughly.
5. Consequences of Breach
Any employee who breaches this policy may face disciplinary action, including dismissal for misconduct or gross misconduct. We also reserve the right to terminate our relationship with any individual or organisation found to be in breach of this policy or involved in modern slavery practices.
This policy reflects our ongoing commitment to ethical conduct, transparency, and compliance with the Modern Slavery Act 2015. It underlines our dedication to preventing all forms of modern slavery in our business operations and supply chains.