Anti-Slavery Policy

Overview

Modern slavery is a crime and a violation of fundamental human rights. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our dealings and relationships.

Modern slavery 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.

We are committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own organisation or in any of our supply chains. We are also committed to ensuring transparency throughout our supply chains, consistent with our obligations under the Modern Slavery Act 2015.

Policy Responsibility

Our Compliance Officer 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 the issue of modern slavery in supply chains.

Individual Responsibility

All individuals must read, understand and comply with this policy. The prevention, detection and reporting of modern slavery in any part of our organisation or supply chains is the responsibility of all those working for us or under our control.

Individuals are required to avoid any activity that might lead to, or suggest, a breach of this policy. The Compliance Officer must be notified as soon as possible if an individual believes or suspects that a conflict with this policy has occurred or may occur in the future.

Our Commitment

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy. We are committed to ensuring no one suffers any detrimental treatment due to reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our organisation or in any of our supply chains.

Breach of this policy

Any individual who breaches this policy will face appropriate action. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.