Modern Slavery Policy

This Statement is made pursuant to Section 54(1) of The Modern Slavery Act 2015, introduced by the UK government to address slavery and human trafficking, and it constitutes our company’s slavery and human trafficking statement. We are committed to ensuring that there is no modern slavery or human trafficking in our business, related supply chains, and services. We act with integrity in all of our business ventures and relationships, and we undertake the appropriate due diligence to identify and prevent the risk of slavery and human trafficking taking place.

 

Purpose

Modern slavery is a violation of fundamental human rights. It is a crime. It can take the form of servitude, forced labour and human trafficking – all of which deprive an individual of their liberty for the purposes of either person or commercial gain. Our company has a zero-tolerance stance when it comes to modern slavery and we ensure that all of our business relationships and dealings are handled in an ethical manner, by putting in place effective systems to prevent such slavery from taking place within our business as well as any third parties with whom we operate. This is in line with our obligations under the Modern Slavery Act 2015.

Scope of Policy

This policy applies to all individuals working for our company or on our behalf in any capacity, including employees, partners, officers, agency workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, business partners or other parties in a supply chain. This policy does not form part of any employee’s contract of employment and we reserve the right to amend it at any time.

Policies and Controls

Our company acknowledges that there is an ongoing risk of slavery in all industries and jurisdictions. Our company has put in place measures to prevent and address this risk through the prohibition of abuse, discrimination and forced labour in its workforce and also by conducting its business in line with all applicable legislation. We recognise the important and value of diversity in the workforce. The principles of fairness, equal opportunity and respect apply to all individuals employed by our company, irrespective of their age, disability, gender, nationality, race, religion, sex or sexual orientation.

Policy Awareness and Responsibility

Management is responsible for enforcing this policy and ensuring that all staff are adequately trained with regards to both the terms of this policy as well as the broader issue of modern slavery as a whole. Our zero-tolerance policy to modern slavery is made available to all third parties through the course of our business dealings, and may be reinforced if appropriate at any stage. The prevention, detection and reporting of any instances of modern slavery in any part of our business is the responsibility of all those employed by our company.

Policy Compliance

You must ensure that you read through and understand this policy in order to comply with it. You must avoid any kind of activity or behaviour which has the potential to contravene this policy. You must notify your manager as soon as possible if you believe or hold any reasonable suspicion that the terms of this policy have been breached or are about to be breached. If you are unsure about whether a particular kind of activity or behaviour constitutes such a breach, you should refer the matter to management. Our company will support anyone who flags up genuine concerns in good faith under this policy, regardless of whether the concern turns out to be true. Individuals who raise concerns of this nature will not be subjected to any detrimental treatment as a result of reporting in good faith any suspicion that they may hold. Detrimental treatment includes disciplinary action, termination of employment, threats or other unfavourable treatment in connection with reporting a concern to management. If you believe you have received any such unfavourable treatment, you should inform the compliance manager immediately. If the matter is not then resolved satisfactorily and you are an employee of our company, you should raise a formal grievance.

Breach of Policy

Any of our employees who are found to be in breach of this policy will be subject to disciplinary action which may result in dismissal. Our company may terminate our relationship with other individuals and third parties working on our behalf if they breach this policy.

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