Introduction
The group of businesses have a zero-tolerance approach to slavery and is committed to preventing acts of slavery and human trafficking from occurring within, and as part of this commitment, impose the same high standards to our contractors, suppliers, and other business partners.
Purpose
The purpose of this policy is to set out a high-level set of processes to seek to ensure that all goods and services provided by the group and its contractors, suppliers, and other business partners, come from businesses which have taken steps to ensure that there is no modern slavery within their supply chain, and to enable us to comply with our obligations under the UK Modern Slavery Act 2015 (the “Act”).
Implementation
To identify and assess potential risk areas in our business and supply chains and to reduce the risk of slavery and human trafficking occurring in our business and supply chains, and to ensure adequate protection for individuals who wish to report suspected violations of the Act or this policy, we shall:
Actively review its procurement practices, as well as all relevant supply relationships, to determine appropriate steps to ensure compliance with the Act, including:
Revising vendor contract templates to require affirmative assurances/certification of compliance with the Act from suppliers.
Reviewing existing suppliers to identify those who may be involved in higher risk areas.
may be necessary to assure that high risk suppliers are compliant with the Act and have taken appropriate steps to ensure compliance in their supply chains.
Updating policies, such that, for example, supplier personnel working on-site at our facilities would be required to carry their passports or other proof of identity, along with their proof of right to work in the UK (where such right would not otherwise be automatic).
We shall provide on-going staff training to ensure that all personnel are aware of the Modern Slavery Act 2015, including its definitions of slavery and human trafficking.
We shall provide an avenue for reporting by staff instances where they suspect a case of slavery or human trafficking.
