modern slavery policy

Introduction

This policy is made pursuant to section 54 of the UK Modern Slavery Act 2015 and sets out the steps we take to prevent Modern Slavery and human trafficking in our business and supply chains.

Slavery, forced labour, servitude and human trafficking are forms of Modern Slavery. These are criminal activities that deprive individuals of their liberty and typically involve financial or other forms of exploitation.

We are committed to conducting our business fairly, ethically and with respect for fundamental human rights. We have a zero-tolerance approach to Modern Slavery and are committed to preventing all forms of Modern Slavery within our business and throughout our supply chains.

This policy applies to all persons working for, or on behalf of, our organisation in any capacity, including employees, directors, workers, consultants, suppliers and service providers.  Failure to comply with this policy may result in disciplinary action, including dismissal, termination of contracts, and/or other legal action.

Our Anti-Slavery Officer (ASO) is the Operations Manager, who has overall responsibility for this policy and its implementation.

Preventing Modern Slavery in Our Business

We take active steps to reduce the risk of Modern Slavery within our operations. These include:

• Carrying out appropriate checks on employees, recruitment agencies and suppliers to understand who is working for, or on our behalf
• Providing all employees with written contracts of employment
• Ensuring employees are paid in accordance with applicable laws
• Complying with all legal obligations relating to working hours, rest breaks, holidays, health and safety, and employee wellbeing
• Requiring all employees to comply with our Employee Code of Conduct and to always behave ethically and responsibly
• Maintaining a Whistleblowing Policy, aimed principally at employees but also available to others, which encourages the reporting of any wrongdoing, including human rights violations such as Modern Slavery

Our Supply Chains and Expectations of Suppliers

We are committed to working with suppliers who share our values and uphold the highest standards of ethical conduct.

If you supply goods or services to us, you must assess your own business and supply chains and confirm to our Anti-Slavery Officer that you:

• Comply with all applicable legal obligations relating to Modern Slavery; and
• Are committed to ensuring that Modern Slavery does not take place within your business or any part of your supply chains

If a supplier breaches this policy, or if Modern Slavery is identified within their business or knowingly within their supply chain, we reserve the right to terminate the contract and pursue appropriate legal remedies.

Reporting Concerns and Whistleblowing

Employees and workers providing services for us must immediately report any suspicions or concerns relating to Modern Slavery in our business or supply chains to the Anti-Slavery Officer.

All reports will be investigated promptly and, where appropriate, escalated to the Director with recommendations for further action.

We are committed to ensuring that no one suffers detrimental treatment as a result of raising a genuine concern in good faith, even if the concern is later found to be unfounded.  Any individual who believes they have suffered such treatment should immediately inform the Anti-Slavery Officer. Employees may also refer to our Grievance and Whistleblowing Policies.

Ongoing Commitment

We are committed to continually reviewing and improving our policies, procedures and due diligence processes to ensure Modern Slavery and human trafficking have no place in our business or supply chains.

This Modern Slavery Policy has been approved by Dawn McFarlane, Director.

It will be reviewed and updated annually to ensure its ongoing effectiveness and compliance with the UK Modern Slavery Act 2015.