Modern Slavery, Anti-Slavery and Human Trafficking Policy
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
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
Jemma O'Neill has overall responsibility for ensuring this policy complies with our legal and
ethical obligations, and that all those under our control comply with it.
Jemma O'Neill 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.
Line managers 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 person
responsible for this policy.
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 your manager 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 of 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
your manager or report it in accordance with our Whistleblowing Policy 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 your manager or Head of Procurement.
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 Head of Procurement 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.
Name: JEMMA O'NEILL
Position: OPERATIONS MANAGER
Date: 21st February 2020