Modern Slavery Policy

Policy 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.
• We are committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our 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 compliance with this policy and the Modern Slavery Act 2015 and we expect that our suppliers will hold their own suppliers to the same high standards.
• This policy applies to all persons working for us or on our behalf in any capacity, including employees, directors, officers, agency workers, seconded workers, volunteers, contractors, external consultants, third-party representatives and business partners.

Responsibility for the Policy

• The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
• Management at all levels have primary and day-to-day responsibility for implementing this 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.
• Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are provided with adequate and regular communications on it and the issue of modern slavery in supply chains.  
   

Breaches of the Policy

• We may terminate our relationship with other individuals and businesses working on our behalf if they breach this policy.