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Modern Slavery policy

Our policy

The company regards social responsibility as core to our culture and processes.  Although we are exempt from the Modern Slavery Act 2015, we feel it is our duty to ensure we comply with the principles of this important legislation and have in place measures to ensure any suppliers do the same.

As an equal opportunities’ employer, we’re committed to creating and ensuring a non-discriminatory and respectful working environment for our staff. Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion.

Due to the nature of our business, we assess ourselves to have a low risk of modern slavery in our supply chains. Our supply chains are limited, and we procure goods and services from a restricted range of UK suppliers that comply with our policy.

For the purpose of this policy exploitation is defined as:

Exploitation is defined as:

  • Slavery
  • Forced labour
  • Sexual exploitation (defined by reference to other UK Acts)
  • Removal of organs
  • Securing services by force, threats, or deception
  • Securing services by any means from a child or vulnerable person (as defined).

Our Modern Slavery policy is intended to ensure and secure, as far as reasonably practicable:

  • All employees are aware of the act, and its requirements
  • All employees have adequate training to ensure they know the common signs of human trafficking, exploitation, forced labour and slavery and how to report these
  • Our supply chain is aware of our stance, and that we have appropriate, robust due diligence measures to ensure any suppliers comply with our policy.
To pursue these objectives, we will:
  • Provide adequate control of risks arising from our activity, and those of our suppliers
  • Provide effective training to ensure employees are aware of the Act’s importance and our personal responsibility and that of the company
  • Include as part of our contracting processes, specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children
  • Require all suppliers, where relevant, to share with us their Modern Slavery statement
  • Review best practice of organisations of our size annually, to ensure we continue to build on our approach
  • Publish this policy on our intranet and external website.
Responsibilities

The Board is responsible for:

  • Ensuring that the company complies with any relevant legislature and regulatory requirements in respect of Modern Slavery Act
  • Ensuring that a comprehensive policy and procedure is in place regarding the recruitment and terms of conditions of employees at work
  • Reviewing the policy at least every three years, or before if legislation or practice changes.

The head of finance and operations is responsible for:

  • Communicating this policy to all employees
  • Ensuring effective and appropriate training is in place for all employees
  • Ensuring that the Board of Directors is made aware of any issues and advising on the budget and resources needed to pursue the policy
  • Reviewing and updating the policy whenever prudent or necessary, and at least every three years otherwise.

All Employees must:

  • Comply with the company’s policy, rules and procedures. Non-compliance may result in disciplinary action against the employee
  • Take all reasonable steps to ensure their own compliance with this and all other relevant policies
  • Report immediately any concerns to the head of finance and operations.

 

Approved: May 2024