Modern 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 labor, and human trafficking, all of which involve depriving a person of their liberty to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships. 

We are also dedicated to implementing and enforcing effective systems and controls to ensure that modern slavery does not occur in any part of our business or supply chains.

We are committed to ensuring transparency in our business and 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 contractors, suppliers, and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory, or trafficked labor, or anyone held in slavery or servitude, whether adults or children, and we expect our suppliers to uphold 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.

2. Responsibility for the Policy

The Director 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 Director has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, addressing any queries, and auditing internal control systems and procedures to ensure they effectively counter modern slavery.

Line managers at all levels are responsible for ensuring that those reporting to them understand and comply with this policy. They are also tasked with providing adequate and regular training on this policy and the issue of modern slavery in supply chains.

Comments, suggestions, and queries regarding this policy 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 are 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 part of our business or supply chains at the earliest possible stage.

If you believe or suspect a breach of this policy has occurred or is likely to occur, you must notify your manager or report it according to our Whistleblowing Policy as soon as possible. If you are unsure about whether a particular act, the treatment of workers, or their working conditions within any tier of our supply chains constitutes modern slavery, raise it with your manager or the Head of Procurement.

We 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 concerns in good faith about modern slavery.

Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavorable treatment related to raising a concern. If you believe you have suffered any such treatment, 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 risks our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us. 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 organizations working on our behalf if they breach this policy.

6. Practices That Create Risk of Modern Slavery

Practices that create the risk of modern slavery can occur at any point in the employment cycle, including recruitment, employment, and exit. 

Examples are provided below:

Recruitment:

• Workers charged illegal or excessive recruitment fees

• Workers uninformed or misinformed about terms of employment

• Workers not provided with understandable, legally compliant written contracts

• Multiple labor brokers and agents from recruitment to employment

• Fraudulently charging fees for travel, health checks, or work documentation

Employment:

• Underpayment of wages, delayed or withheld wage payments, or excessive or illegal wage deductions

• Identity documents and passports confiscated or withheld

• Workers required to stay in company- or broker-controlled housing and unable to enter or leave the premises freely

• Physically abusive or humiliating discipline practices

• Working excessive overtime beyond legal or code of conduct limits

Exit:

• Worker’s visa and work permit tied to a single employer

• Monetary penalties or withholding of wages for early contract termination

• Undocumented migrants threatened with notification to authorities if they leave employment

• Workers forced to pay financial deposits or ‘security’ fees as ‘runaway insurance’