General 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 (“modern slavery”), all of which include the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Policy Aims & Responsibility

The company has a zero-tolerance approach to modern slavery within its business and supply chains.

This policy applies to all persons:

Working for the company, or on our behalf, in any capacity, including employees at all levels, directors, managers, supervisors, contractors, sub-contractors, agency workers, seconded workers, volunteers, interns and agents.

Our contractors, external consultants, agencies, third-party representatives, and business partners and suppliers.

Employers Responsibilities:

• Acting ethically and with integrity in all our business dealings and relationships.
• Implementing, reporting and enforcing effective controls to ensure modern slavery is not taking place anywhere in our business or in any of our supply chains.
• Ensuring there is transparency in our approach to tackling modern slavery in our business and in our supply chains consistent with our disclosure obligations under the Modern Slavery Act 2015.
• We expect the same high standards from all of our suppliers, contractors, sub-contractors and labour force.
• As part of our contracting process, we include specific prohibitions against modern slavery, and we expect that our suppliers will hold their own suppliers to the same high standards.

Identifying Slavery

Modern slavery may be found in our business, for example, a cleaning and catering supplier, our material supply chains, and outsourced activities, particularly to jurisdictions that may not have adequate modern slavery safeguards.

There is no typical victim of modern slavery, and some victims do not understand they have been exploited and are entitled to help and support. However, the following key signs could indicate that someone may be a victim of modern slavery or human trafficking:

• The person is not in possession of their own passport, identification or travel documents.
• The person is acting as though they are being instructed or coached by someone else.
• The person allows others to speak for them when spoken to directly.
• The person is dropped off and collected from work.
• The person is withdrawn or appears frightened.
• The person does not seem to be able to contact friends or family freely.
• The person has limited social interaction or contact with people outside of their immediate environment.
• The above list is not exhaustive.

A person may display a number of the indicators set out above, but they may not necessarily be a victim of slavery or trafficking.

Responsibility for this Policy & Compliance

• The managing director has overall responsibility for ensuring this policy complies with the company’s legal and ethical obligations.
• The company legal representative has primary responsibility for dealing with this policy and any queries about it.

Employees Responsibilities:

• All employees must comply with this policy.
• Report anything that they feel is suspicious.
• All suppliers’ contractors, sub-contractors and labour must comply with this policy.

Reporting Slavery

Company staff and suppliers must report any incidence or suspicion of modern slavery at the earliest possible stage to:

• If you are a member of employee, your manager or supervisor.
• If you are a supplier, your primary manager or supervisor at your company.

Breaches of This Policy

Any employees, contractors, sub-contractors and labour who breaches this policy may face disciplinary action, which could result in dismissal for misconduct or gross misconduct or be removed from our approved contractor or sub-contractor list.

The company may terminate its relationship with a supplier if it is in breach of this policy. Alternatively, the company may elect to work with the supplier to resolve such issues.

This policy will be subject to regular monitoring, inspection and review with appropriate action carried out should further risk or hazards be identified.