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Modern Slavery Policy

Modern Slavery and Human Trafficking

Modern slavery is a term used to encompass slavery, servitude, forced and
compulsory labour, bonded and child labour and human trafficking. Human
trafficking is where a person arranges or facilitates the travel of another person
with a view to that person being exploited. Modern slavery is a crime and a violation
of fundamental human rights.


We shall be a company that expects everyone working with us or on our behalf to
support and uphold the following measures to safeguard against modern slavery:

• We have a zero-tolerance approach to modern slavery in our organisation and
our supply chains.

• The prevention, detection and reporting of modern slavery in any part of our
organisation or supply chain is the responsibility of all those working for us or on
our behalf. Workers must not engage in, facilitate or fail to report any activity that
might lead to, or suggest, a breach of this policy.

• We are committed to engaging with our stakeholders and suppliers to address
the risk of modern slavery in our operations and supply chain.

• We take a risk based approach to our contracting processes and keep them
under review. We assess whether the circumstances warrant the inclusion of
specific prohibitions against the use of modern slavery and trafficked labour in
our contracts with third parties. Using our risked based approach we will also
assess the merits of writing to suppliers requiring them to comply with our Code
of Conduct, which sets out the minimum standards required to combat modern
slavery and trafficking.

Modern Slavery

(Anti-slavery & Human Trafficking) Policy
• Consistent with our risk based approach we may require:
• Employment and recruitment agencies and other third parties supplying
workers to our organisation to confirm their compliance with our Code of
• Suppliers engaging workers through a third party to obtain that third
parties’ agreement to adhere to the Code.

• As part of our ongoing risk assessment and due diligence processes we will
consider whether circumstances warrant us carrying out audits of suppliers for
their compliance with our Code of Conduct.

• If we find that other individuals or organisations working on our behalf have
breached this policy we will ensure that we take appropriate action. This may range
from considering the possibility of breaches being remediated and whether that
might represent the best outcome for those individuals impacted by the breach to
terminating such relationships.

We will review this policy on a regular basis.

Issued by: Chris Edwards

Authorised by: Darryl Gartley

Created Date: 01/07/2020

Issue No: 1