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 will implement and enforce effective systems and controls to ensure modern slavery is not taking place in our own business and supply chains. These statements have endorsement of the Board of Directors and will be vigorously enforced. All employees, wherever they are located in the world, are expected to comply with this policy in full.

Modern Slavery

Slavery is illegal and a violation of human rights.  There are many forms of modern slavery including; forced labour, child labour, exploitation, being controlled by an employer, debt bondage, being physically constrained, being sold or treated as a commodity and having restrictions on freedom of movement.  These acts involve a person losing their freedom by being exploited by another for personal or commercial gain.

Supply Chain

We expect our contractors, suppliers and other business partners to comply with the Modern Slavery Act 2015 and to uphold high standards in all business practices. This statement is reinforced within our Supplier Code of Conduct. We will not knowingly deal with any business involved in the use of staff sourced from forced, compulsory or trafficked labour, or anyone held in slavery or servitude.

Employees

All employees are responsible for the prevention, detection and reporting of modern slavery in any part of our business or supply chains.  Employees are required to avoid any activity that might lead to a breach of this policy, and the Modern Slavery Act 2015.

Employees are encouraged to raise concerns about suspicions of Modern Slavery in any parts of our business or supply chains at the earliest possible stage. Employees must notify the Managing Director as soon as possible, if they believe that, a conflict with, or breach of, this policy has occurred, or may occur, in the future.

If employees are unsure as to whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any, or all of, the various forms of modern slavery you must notify the Managing Director.

Employees should consult with the Managing Director if they suspect that a company employee is engaged in unacceptable or unethical conduct. Our Whistleblowing Policy can also be seen for full details on this process.

Relevant Legislation

In setting out the principles included in this policy, particular attention has been paid to the requirements of:

	The Modern Slavery Act 2015. The company is registered in the UK, and this law has particular relevance to the manner in which the company conducts itself;
	The Trade Facilitation and Trade Enforcement Act 2015. This Act is in effect in the USA. Adherence to its requirements is mandatory for many of the company’s clients and its requirements are fully adopted by the company.

 

Application

The Managing Director has overall responsibility for the application of this policy.

The company will make this policy readily available on the company’s website and intranet for all interested parties. The policy will also form part of a new employee’s induction training programme.

The internal audit programme will audit compliance against this policy, and other company policies, at regular intervals. Compliance will also form part of regular legal reviews, by the company legal compliance advisor.

Failure to ensure compliance with this policy could lead to the following consequences for the company:

 

	Criminal or civil liabilities for the company including fines and imprisonment;
	Serious reputational damage including media comment;
	Debarment from tendering for public sector contracts, and;
	The unenforceability of contracts entered into as a result of modern slavery or other illegality.

   Failure to ensure compliance with this policy could lead to the following consequences for employees:

 

	Personal criminal liability followed by fines or imprisonment;
	Disciplinary action initiated by the company, including dismissal;
	Personal reputational damage.

Employees in any case of uncertainty, or any cases of doubt, surrounding how to apply this policy, should speak with the Managing Director.

The policy will be reviewed annually, or earlier, should there be any significant changes, such as to governing legislation.

Sarah Spivey

Managing Director

January 22nd 2021