We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:
We encourage all workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
Employee code of conduct:
Our code makes clear to employees the actions and behaviour expected of them. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.
Procurement code of conduct:
We are committed to ensuring that suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the code and improve their workers’ working conditions. However, serious violations of our supplier code of conduct will lead to the termination of the business relationship.
Agency workers policy
We use only specified, reputable employment agencies to source labour and always verify the practices of any new agency we are using before accepting workers from that agency.
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. All staff are required to avoid any activity that might lead to a breach of this policy.
If staff believe or suspect a breach of or conflict with this policy has occurred or may occur, they must notify their line manager. All staff are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business or supply chains as soon as possible.
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 or victimisation as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of our business or supply chains.
Training and communication
Regular training on this policy, and on the risk that the business faces from modern slavery in supply chains, will be provided to staff as necessary, so that they know how to identify exploitation and modern slavery and how to report suspected cases.
Our zero tolerance approach to modern slavery must be communicated to all suppliers, contractors and other business partners when entering into new or renewed contracts with them.
Breach of the policy
Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.
We may terminate commercial relationships with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery.
We shall continue to review the effectiveness of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains.
This statement has been approved by the Company’s Board of Directors on behalf of the Group. A new statement will be published annually.