ANTI-SLAVERY 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 to exploit them for personal or commercial gain.
The Company has 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 our contractors, suppliers and other business partners, and as part of our contracting processes, in the coming year we will 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 partners.
This policy does not form part of any employee’s contract of employment, and we may amend it at any time.
Responsibility for the policy
The Company has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Company 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.
Management 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 Managing Director.
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 line manager OR a company Director 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 line manager or company director.
You should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains.
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 line manager or company director.
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 because 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 your line manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the current employee handbook.
Communication & 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 updates will be provided using established methods of communication between the business and you. 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.
Key Performance Indicators
- Training Coverage: The percentage of employees who have completed training on modern slavery and human trafficking. This KPI helps ensure that all employees are aware of the company’s policies and procedures regarding modern slavery.
- Training Effectiveness: The results of post-training assessments to measure the understanding and retention of the training material. This can include quizzes or surveys conducted immediately after the training and follow-up assessments after a certain period.
- Incident Reporting: The number of reported incidents of modern slavery or human trafficking before and after the training. A decrease in incidents may indicate the effectiveness of the training.
- Employee Feedback: Collecting feedback from employees on the training sessions to identify areas for improvement and ensure the training is engaging and informative
Assessing during each stage of the procurement process
- Pre-Procurement: During this stage, the organization should conduct a risk assessment to identify potential areas where modern slavery could occur. This includes evaluating the supply chain and identifying high-risk suppliers. The company should also establish clear policies and expectations regarding modern slavery and communicate these to potential suppliers.
- Supplier Selection: When selecting suppliers, the organization should include criteria related to modern slavery in the evaluation process. This involves assessing suppliers’ policies, practices, and track records in preventing modern slavery. The company should also require suppliers to complete a modern slavery assessment and provide evidence of compliance.
- Contracting: In the contracting stage, the organization should include specific clauses in contracts that prohibit the use of forced, compulsory, or trafficked labour. These clauses should outline the consequences of non-compliance and require suppliers to cascade these requirements down their own supply chains.
- Supplier Management: Once contracts are in place, the organization should regularly monitor and audit suppliers to ensure compliance with modern slavery policies. This includes conducting site visits, reviewing supplier practices, and engaging with workers to identify any issues. The company should also provide training and support to suppliers to help them address modern slavery risks.
- Performance Review: The organization should regularly review the performance of suppliers in relation to modern slavery. This involves analysing data on incidents, conducting follow-up assessments, and seeking feedback from workers and other stakeholders. The company should use this information to make informed decisions about continuing or terminating supplier relationship.
Purchasing Practices Assessment
- Aggressive Pricing: The company will evaluate whether pricing strategies consider sustainable production costs by conducting regular audits and supplier assessments. This ensures that suppliers are not forced into unsustainable practices to meet low pricing demands.
- Short Lead Times: The organization will monitor lead times and assess their impact on suppliers’ ability to meet orders without resorting to exploitative labor practices. This includes reviewing supplier performance and capacity to handle short lead times.
- Late High-Volume Orders: The company will track the frequency and impact of late high-volume orders on suppliers. This involves analysing order patterns and their effects on suppliers’ operations and labour conditions.
- Inaccurate Forecasting: The organization will assess the accuracy of its demand forecasting and its impact on suppliers. This includes evaluating the alignment between forecasted and actual orders and the resulting strain on suppliers.
- Late or Extended Payments: The company will review payment terms and practices to ensure timely payments to suppliers. This involves monitoring payment schedules and addressing any delays that could negatively impact suppliers’ financial stability1.
- Withdrawing from Contracts Last Minute: The organization will assess the frequency and reasons for withdrawing from contracts at the last minute. This includes evaluating the impact on suppliers and implementing measures to minimize such occurrences.
- Unfair Penalties for Not Meeting Orders Despite Last Minute Changes: The company will review its penalty policies to ensure they are fair and do not unduly penalize suppliers for circumstances beyond their control. This involves assessing the fairness and transparency of penalty clauses in contracts.
- Accuracy of Technical Specifications: The organization will evaluate the accuracy and clarity of technical specifications provided to suppliers. This includes reviewing feedback from suppliers and making necessary adjustments to ensure specifications are clear and achievable.
Reporting of suspected instances
- Reporting: Employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of the business or supply chains at the earliest possible stage. They must notify their line manager or a company director as soon as possible if they believe or suspect that a conflict with the anti-slavery policy has occurred or may occur in the future.
- Support and Guidance: Where appropriate, and with the welfare and safety of local workers as a priority, the company will give support and guidance to suppliers to help them address coercive, abusive, and exploitative work practices in their own business and supply chains.
- Encouraging Openness: The company aims to encourage openness and will support anyone who raises genuine concerns in good faith under the anti-slavery policy, even if they turn out to be mistaken. The company is committed to ensuring no one suffers any detrimental treatment because of reporting in good faith their suspicion that modern slavery is or may be taking place.
- Detrimental Treatment: Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. If an employee believes they have suffered any such treatment, they should inform their line manager immediately. If the matter is not remedied, and they are an employee, they should raise it formally using the company’s Grievance Procedure.
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.
