Anti-Slavery Policy

This Human Traffic and Slavery Policy (this Policy) exists to set out our responsibilities with regard to observing and upholding our zero-tolerance position on human trafficking and slavery.

We are committed to conducting our business in an ethical and honest manner and to implementing and enforcing systems that ensure human trafficking and slavery is prevented at all times. Modern slavery is a crime and a violation of fundamental human rights. We recognise that it can take 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.

POLICY STATEMENT

We have a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and strive to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere within our organisation.

We are also committed to ensuring that there is transparency in our business and that our approach is consistent with our disclosure obligations under all relevant applicable Modern Slavery laws. 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 standards.

WHO IS COVERED BY THIS POLICY?

This Policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third-parties), or any of our subsidiaries or their employees, no matter where they are located. This Policy also applies to our Officers, Trustees, Board, and/or Committee members at any level.

In the context of this Policy, 'third-party' refers to any individual or organisation we meet and work with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.

Any arrangements made with a third-party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to human trafficking and slavery.

MITIGATING ACTIONS

As part of our initiative to identify and mitigate the risk of human trafficking and slavery practices we have in systems in place to routinely:

• Identify and assess potential risk areas in our business and supply chains;
• Mitigate the risk of slavery and human trafficking occurring in our supply chains;
• Monitor potential risk areas in our supply chains; and
• Protect any employee or person reporting any suspicions or knowledge of instances of human trafficking or slavery.

HOW TO RAISE A CONCERN

If you suspect that there is an instance of human trafficking or slavery activities, you are encouraged to raise your concerns at as early a stage as possible.

COMMUNICATION

This Policy and our zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third-parties at the outset of business relations, and as appropriate thereafter.

RECORD KEEPING

We keep detailed and accurate records of all reports made and actions taken in relation to concerns raised regarding human trafficking or slavery.

MONITORING AND REVIEWING

Our internal control systems and procedures designed to prevent human trafficking and slavery are subject to regular audits to ensure that they are effective in practice. Any need for improvements are applied as soon as possible.

AWARENESS-RAISING PROGRAMME

As well as training key staff, the organisation also raises awareness of modern slavery issues by developing information for cascading and circulating in our employee intranet, including:

• The basic principles of the Modern Slavery Act 2015;
• How employees can identify and prevent slavery and human trafficking;
• What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation;

VERIFICATION

All new relationships with suppliers are subject to standard due diligence requirements such as proof of business address, proof of ID, and proof of bank account. If a supplier is found to exhibit a risk of modern slavery practices in its operations, our procurement process requires immediate further investigation to take place with the outcome that the relationship be immediately terminated should any presence of slavery in the supplier's operations be confirmed.

Due diligence relating to customers requires confirmation that they are over 18 years of age during the signup process.