Anti-Slavery & Human Trafficking Policy

Issue date 15/01/2019
The company directors will review this policy on an annual basis regarding effectiveness, legislative compliance, organisational changes and general improvements.

 

Legislation
The Modern Slavery Act 2015

The law requires that any commercial organisation, which supplies goods or services, and operates a business or part of a business in the UK, and has total annual turnover in excess of £36m, must produce a slavery and human trafficking statement for each financial year of the organisation.

The statement must set out the steps to be taken during each financial year to ensure that modern slavery is not occurring in their supply chain and in their own organisation.  If a business fails to produce a slavery and human trafficking statement for a particular financial year it could ultimately receive an unlimited fine.

Note
The annual turnover of the company is currently less than the £36m threshold and is therefore not legally required to produce a slavery and human trafficking statement.  The company however has adopted a proactive approach by preparing the policy statement below.

Whilst our current supply chain is mainly limited to organisations within the UK and all our activities are solely undertaken in the UK, our overall policy is to ensure that neither the company nor its supply chain is involved in any forms of slavery and human trafficking.

Policy
The company will not permit, condone or otherwise tolerate any form of slavery or human trafficking undertaken by its associated parties – customers, supplies, employees, subcontractors or any other entity it may have dealings with.

The company is also committed to preventing any form of slavery or human trafficking in its activities and to ensure that its associated parties do not engage in such activities.

Our policy is underpinned by the following principles:

  • Engage only with reputable associated parties who do not participate in any form of slavery or human trafficking.
  • Undertake appropriate due diligence on associated parties, e.g. sub-contractors, to ensure that there is no perceivable risk of slavery or human trafficking taking place.
  • Inform the relevant authorities, in the event that an associated party is suspected of any transgressions and terminate business arrangements with the organisation(s) in question.
  • Avoid contract with anyone who has been identified to be in breach of slavery and/or human trafficking legislation.
  • To raise awareness of slavery and human trafficking by communicating this Policy to employees and all other relevant parties that the company may come into contact with.
  • To review this policy on an annual basis and reaffirm that all employees understand, and adhere to the intent of this policy.

We also expect applicable associated parties to:

  • Establish a suitable policy and management system to ensure compliance with legislative requirements.
  • If requested, provide appropriate proof of having a policy in place.