Anti-Slavery Policy

Policy statement

The Company recognises that modern slavery remains a hidden blight on our global society. 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

About this policy

The purpose of this policy is to:

• alert staff to the risks, however small, in our business and in the wider supply chain and to prevent any such activity in our business operations;
• set out our responsibilities, and of those working for and on our behalf, in observing and upholding our position on modern slavery and human trafficking; and
• provide information to those working for and on our behalf on how to identify and report concerns regarding modern slavery and human trafficking.

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.

Responsibilities

Staff are expected and encouraged to report concerns or suspicions to management 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 line manager.

Company activities are varied through multiple disciplined areas and sectors and likewise we have a multi-disciplined supply chain to support us through the different aspects and provisions of our business.

Formal procedures concerning slavery and human trafficking have been established, including disciplinary procedures where they are breached. Additional procedures ensure that this policy is understood and communicated to all levels of the Company, and that it is regularly reviewed to ensure its continuing suitability and relevance to Company activities.

The Company will identify and mitigate risk of modern slavery in the following ways (but not limited to):-

• stringent vetting and investigation of our supply chain (contractors, sub-contractors, policies, contracts etc.).
• continually auditing & reviewing our practices for ensuring that all employees are paid at least the minimum wage and have the right to work in the UK;
• encouraging the reporting of concerns;
• protecting whistleblowers;
• never knowingly supporting or dealing with any business involved in slavery or human trafficking; and
• having a zero tolerance to slavery and human trafficking.

We expect all those in our supply chain and contractors comply with our values. To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff.

We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains.

• Completion of Audits by Directors, Managers, Safety managers and Safety Advisors;
• Use of labour monitoring and payroll systems; and
• Level of communication and personal contact with the next link in the supply chain and their understanding of, and compliance with, our expectations.

Breaches

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.