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Modern Slavery Policy

v2.0

Modern Slavery is a criminal offence under the Modern Slavery Act 2015. Modern slavery can occur in various forms, including servitude, forced or compulsory labour and human trafficking, all of which have common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. This policy sets out the Company’s aim of the prevention of opportunities for modern slavery to occur within its businesses or supply chain. This policy’s use of the term “modern slavery” has the meaning given in the Act.

The company has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or those of our suppliers.

The company acknowledges the provisions of the Modern Slavery Act 2015 and will ensure transparency within its organisation and with suppliers of goods and services to the organisation, the company is satisfied from its own due diligence there is no evidence of any act of modern-day slavery or human trafficking within its own organisation.

In respecting the dignity and rights of all employees the company applies the prohibitions, checks and permissions below to its operations. Specifically, it:

  • ensures worker identity or immigration documents are verified in line with applicable legislation, with copies of related documents only being retained by authorised personnel for specific purposes and time, and prohibits the withholding of such identity or immigration items, including passports, visas and travel documents which are immediately returned to the worker if verified in person;

  •  prohibits the use of recruiters or labour brokers, including child labour, who do not comply with the local labour laws of the country in which recruiting occurs;

  • ensures that prior to local hiring or in the event of relocation workers are provided with detailed and accurate written contracts of employment or similar work papers in a language understood by them, clearly setting out both parties’ rights and responsibilities with regard to payment of wages, working hours, valid grounds for termination, and other issues related to the prevention of forced labour; and

  • permits workers, including migrant workers, all of whom are employed by their own will, to cancel their contracts of employment or similar work contracts at any time with no financial penalty, subject to giving reasonable notice in accordance with national labour laws or collective agreement.

As part of the company’s due diligence processes into modern slavery and human trafficking, the supplier approval process incorporates a review of the controls undertaken by the supplier.

Imported goods from sources outside the UK and EU are potentially more at risk of slavery and human trafficking issues. The level of management control required for these sources will be continually monitored. The company will not knowingly support or deal with a business (contractors, suppliers or business partners) involved in modern slavery or human trafficking. We expect our suppliers to hold their own suppliers to the same high standards.

The ultimate responsibility for the prevention and prevention of modern slavery rests with the Company’s leadership. The board of directors of the Company has overall responsibility for ensuring this policy and its implementation comply with our legal and ethical obligations.

Following its initial adoption, this policy will be reviewed by the Company’s Board of Directors on a regular basis (at least annually) and may be amended from time to time.

Please find a signed copy of this statement here.

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