Modern Slavery Policy

Our Policies on Slavery and Human Trafficking

Our policy is that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Due diligence

As part of our initiative to identify and mitigate risk –

  1. Where viable, we run each subsidiary or business premise in the same way to ensure optimum control of the work environment;
  2. We limit the geographical scope of our premises to ensure optimum supervision of the use of our properties;
  3. Where possible we build long standing relationships with local suppliers and customers and make clear our expectations of business behaviour;
  4. With regards to national or international suppliers, our point contact is preferably with a UK company or branch and we expect these entities to have suitable anti-slavery and human trafficking policies and processes. We expect each entity to, at least, adopt ‘one-up’ due diligence on the next link in the chain. It is not practical for us to have a direct relationship with all suppliers in the chain.
  5. We have in place systems to encourage the reporting of concerns and the protection of whistle blowers, and these are covered in other policies.

Supplier Adherence to our Policy

We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain and all of our contractors comply with our values. The Board of Directors are responsible for compliance in their respective departments and for their own supplier relationships.

Our Effectiveness in Combating Slavery and Human Trafficking

We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

  • Completion of HR Audit on all employees and contractors on an annual basis;
  • Use of labour monitoring and payroll systems;
  • Level of communication and personal contact with the next link in the supply chain and their understanding of, and compliance with, our expectations.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our group’s slavery and human trafficking statement.