Modern slavery Policy

We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or those of our suppliers.

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Modern Slavery Policy

We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.

Whilst recognising our statutory obligation to set out the steps we have taken to ensure that modern slavery and human trafficking is not taking place in our supply chains, we acknowledge that we do not control the conduct of individuals and organisations in our supply chains. However, we have a suite of Company policies (including Business Ethics, Corporate Social Responsibility, Code of Conduct, Discipline and Grievance and Whistleblowing Policy) that define what is acceptable and expected in terms of behaviour in our Company, and all our employees are managed within these parameters.

This approach is reflected in the management of the supplier relationships too. We expect the same high standards from all of our contractors, suppliers and other business partners, and we are evolving and updating our contracting processes to include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect our suppliers to hold their own suppliers to the same high standards.

All prospective employees will be interviewed against a set of core competencies that we deem to be inextricably linked to our organisations core values. Once hired, adherence to Company expectations in terms of conduct, behaviour and performance forms part of all team members’ obligations under their contract of employment.

At point of hiring, all new employees will be referenced (wherever possible) and will undergo a Company induction and on the job training which will outline the processes and procedures

All processes and procedures related to recruitment service provision (both internal and external) will be defined in such a way as to mitigate the risk of modern slavery occurring. These processes will include (but will not be limited to) Right to Work Checks, provision of certain personal information before starting work

For the avoidance of doubt, the Company Whistleblowing policy will be amended to cover concerns of Modern Slavery and/or Human Trafficking.

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 as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. The Company will accept and take seriously concerns communicated anonymously.

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Following its initial adoption, this Anti-Slavery and Human Trafficking Policy will be reviewed by the Company’s Senior Directors and the cross functional team nominated by the business on a regular basis (at least annually) and may be amended from time to time.