1. POLICY STATEMENT
1.1 Modern slavery is a serious crime and a violation of basic human rights. It includes practices such as slavery, servitude, forced and compulsory labour, and human trafficking. These forms of exploitation all involve depriving a person of their freedom to exploit them for personal or commercial gain. We maintain a zero-tolerance policy toward modern slavery and are dedicated to conducting all our business activities ethically, with integrity, and in full compliance with human rights. We are committed to implementing and enforcing robust systems and controls to prevent any occurrence of modern slavery in our operations or supply chains.
1.2 We are equally committed to transparency in our operations and our approach to tackling modern slavery throughout our supply chains, in line with the requirements of the Modern Slavery Act 2015. We expect the same high standards from all our contractors, suppliers, and business partners. As part of our procurement processes, we prohibit the use of forced, compulsory, or trafficked labour, as well as slavery or servitude, whether involving adults or children and also prohibit withholding identity and immigration documents and charging workers recruitment fees. We also expect our suppliers to enforce similar standards with their own suppliers.
1.3 This policy applies to all individuals working for or on behalf of our company in any capacity, including employees at all levels, directors, officers, agency workers, contractors, external consultants, third-party representatives, and business partners.
1.4 This policy does not form part of any employee’s employment contract and may be amended at any time.
2. RESPONSIBILITY FOR THE POLICY
2.1 The Managing Director holds overall responsibility for ensuring this policy meets legal and ethical obligations, and for ensuring compliance across the organization.
2.2 Managers have primary responsibility for the day-to-day implementation of this policy, including monitoring its effectiveness, responding to queries, and auditing internal control systems to ensure they effectively prevent modern slavery. Managers at all levels are responsible for ensuring their teams understand and comply with this policy and for providing regular training on it, as well as on the issue of modern slavery in supply chains.
2.3 Employees are encouraged to provide feedback on this policy and suggest improvements. Any comments, suggestions, or concerns should be directed to the manager.
3. COMPLIANCE WITH THE POLICY
3.1 All employees and individuals working on behalf of the company must read, understand, and comply with this policy.
3.2 Preventing, detecting, and reporting modern slavery in any part of our operations or supply chains is the responsibility of everyone in the company. Employees are expected to avoid any actions or situations that could lead to, or suggest, a breach of this policy.
3.3 If you believe or suspect that there has been, or may be, a breach of this policy, you must report it to your manager as soon as possible.
3.4 Employees are encouraged to raise any concerns or suspicions about modern slavery within any part of our operations or supply chains, regardless of supplier tier. If you suspect a breach of this policy, you must report it immediately. We will support our suppliers in addressing any coercive, abusive, or exploitative practices in their operations and supply chains, prioritizing the welfare and safety of workers.
3.5 If you are uncertain whether a specific action, treatment of workers, or working conditions within any tier of our supply chain constitutes modern slavery, consult with your manager for guidance.
3.6 We encourage an open environment and will support anyone who raises genuine concerns in good faith under this policy, even if it turns out to be a misunderstanding. We are committed to ensuring that no one will face any negative consequences for reporting in good faith suspicions of modern slavery within our business or supply chains. Negative treatment includes dismissal, disciplinary action, threats, or other unfavorable actions related to raising a concern. If you believe you have faced such treatment, you should report it to the manager immediately. If the issue is not resolved,employees should follow the company’s Grievance Procedure.
4. COMMUNICATION AND AWARENESS OF THIS POLICY
4.1 Training on this policy, as well as the risks associated with modern slavery in our supply chains, will be part of the onboarding process for all new employees. Regular refresher training will be provided as necessary.
4.2 Our zero-tolerance stance on modern slavery will be communicated to all suppliers, contractors, and business partners at the outset of any business relationship and reinforced as needed throughout our ongoing relationship.
5. BREACHES OF THIS POLICY
5.1 Any employee who violates this policy will face disciplinary action, which could include dismissal for misconduct or gross misconduct.
5.2 We reserve the right to terminate relationships with any individuals or organizations acting on our behalf who violate this policy.