Anti Slavery Policy Statement
Our supply chains
Our supply chains include self-employed people and consultants and volunteers as well as companies.
We expect organisations and individuals from whom we procure products and services and other companies we engage with to ensure their goods, materials and labour related supply chains:
- Fully comply with the Modern Slavery Act 2015; and are
- Transparent, accountable and auditable; and are
- Free from ethical ambiguities
Individuals with evidence of non-compliance with the Modern Slavery Act in connection with our supply chains are encouraged to follow the reporting procedure which will be outlined in our Whistleblowing Policy.
Our policy on slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery and Human Trafficking 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 processes for slavery and human trafficking
We have in place arrangements to:
- Identify and assess potential risk areas in our supply chains
- Mitigate the risk of slavery and human trafficking occurring in our supply chains
- Monitor potential risk areas in our supply chains
- Protect whistle blowers
Supplier adherence to our values
We have zero tolerance to slavery and human trafficking. To ensure all contractors and those in our supply chain comply with our values we have in place supply chain overview processes managed by the relevant cross-functional representatives from the following departments:
- Our Board Level Team
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we will provide training to relevant staff during their induction training. All Directors will be briefed on the subject and we have supply chain qualified specialists on the board.
Our effectiveness in combating slavery and human trafficking
We are in the process of:
- Agree responsibilities for this policy and statement and received will be a condition of entry onto our boards and therefore all our Directors and Senior Management Team will be asked to support it with a zero tolerance for refusal.
- Give responsibility and awareness training to members of staff who manage our relationships with our supply chain and contractors.We are a learning organsation and all our team members are required to undertake regular training.
- Raising awareness to key members of staff who regularly interact with our supply chain and contractors.
- Incorporate the Anti-Slavery and Human Trafficking Policy in our standard set of Company policies and as part of our induction programme for all new team members and volunteers and staff.
- Seek to impose in new contracts that we enter into provisions for termination in the event of a modern slavery or human trafficking compliance breach by suppliers or contractors. This may be structured to cover termination for breach of any law.
- Act promptly when a compliance breach has been identified.
- Prepare the statement on an annual basis.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2018. It may be updated to improve it at any time on an on going basis as more learning comes to light to try to stamp this out thoroughly round the world.
This policy joins our other policies-
4 Women, Gender and Harrassment
These have been in operation for 10 years and will be posted on this website shortly.