Anti-Modern Slavery 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 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.
We operate to high professional standards and remain committed to ensuring there is no modern slavery or human trafficking in the business. The business policies and procedures have been reviewed and an Anti-Modern Slavery Policy has been introduced. The 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.
As part of an ongoing process, suppliers will be provided with a copy of this statement and the policy.
Risk Assessment and Effectiveness
Reasonable and practical checks, to test whether our standards are being adhered to by our suppliers and that local legislation and regulations are complied with, will be carried out. Any instances of non-compliance will be dealt with on a case-by-case basis and any remedial actions tailored appropriately; to date, no such instances of non-compliance have arisen.
The Operations Director has primary and day-to-day responsibility for implementing the 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.
Communication and Awareness
Training on the 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 regular training will be provided as necessary.
This statement is made pursuant to Section 54, Part 6 of the Modern Slavery Act 2015 for the financial year ended 1 April 2018. It has been approved by the Board of Directors, who will review it on an annual basis making updates as necessary.