Anti-slavery and human trafficking policy

  1. Policy statement

    1. 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 are committed to acting ethically and
      with integrity in all our business dealings and relationships and to implementing and
      enforcing effective systems and controls to ensure modern slavery is not taking place
      anywhere in our own business or in any of our supply chains

    2. 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 business partners, and as part
      of our contracting processes, we include specific prohibitions against the use of forced,
      compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or
      children, and we expect that our suppliers will hold their own suppliers to the same high

    3. This policy applies to all persons working for us or on our behalf in any capacity,
      including employees at all levels, directors, officers, agency workers, seconded workers,
      volunteers, interns, agents, contractors, external consultants, third-party representatives
      and business partners.

    4. This policy does not form part of any employee’s contract of employment and we may
      amend it at any time.

  2. Responsibility for the policy

    1. 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.

    2. Charlie Kingdon (Managing Director) has 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.

    3. Management at all levels are responsible for ensuring those reporting to them understand
      and comply with this policy and are given adequate and regular training on it and the issue
      of modern slavery in supply chains.

    4. You are invited to comment on this policy and suggest ways in which it might be
      improved. Comments, suggestions and queries are encouraged and should be
      addressed to the Charlie Kingdon.

  3. Compliance with the policy

    1. You must ensure that you read, understand and comply with this policy.
    2. The prevention, detection and reporting of modern slavery in any part of our business or
      supply chains is the responsibility of all those working for us or under our control. You are
      required to avoid any activity that might lead to, or suggest, a breach of this policy.

    3. You must notify your manager soon as possible if you believe or suspect that a conflict
      with this policy has occurred, or may occur in the future.

    4. You are encouraged to raise concerns about any issue or suspicion of modern slavery in
      any parts of our business or supply chains of any supplier tier at the earliest possible

    5. If you believe or suspect a breach of this policy has occurred or that it may occur you
      must notify your manager as soon as possible. You should note that where appropriate,
      and with the welfare and safety of local workers as a priority, we may give support and
      guidance to our suppliers to help them address coercive or exploitative work practices
      in their own business and supply chains.

    6. If you are unsure about whether a particular act, the treatment of workers more
      generally, or their working conditions within any tier of our supply chains constitutes any
      of the various forms of modern slavery, raise it with your manager.

    7. We aim to encourage openness and will support anyone who raises genuine concerns in
      good faith under this policy, even if they turn out to be mistaken. We are committed to
      ensuring no one suffers any detrimental treatment as a result of reporting in good faith
      their suspicion that modern slavery of whatever form is or may be taking place in any
      part of our own business or in any of our supply chains. Detrimental treatment includes
      dismissal, disciplinary action, threats or other unfavourable treatment connected with
      raising a concern. If you believe that you have suffered any such treatment, you should
      inform the compliance manager immediately. If the matter is not remedied, and you are
      an employee, you should raise it formally.

  4. Communication and awareness of this policy

    1. Training on this policy, and on the risk our business faces from modern slavery in its
      supply chains, forms part of the induction process for all individuals who work for us, and
      regular training will be provided as necessary.

    2. Our commitment to addressing the issue of modern slavery in our business and supply
      chains must be communicated to all suppliers, contractors and business partners at the
      outset of our business relationship with them and reinforced as appropriate thereafter.

  5. Breaches of this policy

    1. Any employee who breaches this policy will face disciplinary action, which could result in
      dismissal for misconduct or gross misconduct.

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