Modern Slavery Policy

Modern slavery is a crime and a violation of fundamental human rights. It encompasses various forms, including slavery, servitude, forced and compulsory labour, and human trafficking. These forms are unified by depriving a person’s liberty by another to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships. We will implement and enforce effective systems and controls to ensure modern slavery is not taking place in our own business or our supply chain. We are also committed to maintaining transparency in our company and our approach to tackling modern slavery throughout our supply chain. We expect the same high standards from our contractors, suppliers, and other business partners. 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. We expect our suppliers to hold their suppliers to these high standards.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, external consultants, third-party representatives, and business partners. This policy is not part of any employee’s employment contract and may be amended at any time.

Responsibility for the policy

The Operations team is responsible for ensuring that this policy complies with our legal and ethical obligations and that all those under our control comply. The Group Purchasing Director is primarily responsible for implementing this policy, monitoring its use and effectiveness, addressing any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery. Management at all levels is responsible for ensuring those reporting to them understand and comply with this policy and are provided with any necessary training.

Compliance with the policy

You must ensure that you read, understand, and comply with this policy. The prevention, detection, and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control. You must avoid any activity that might lead to or suggest a breach of this policy. You must notify your manager or the Procurement Department as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or the supply chains of any supplier tier at the earliest possible stage. If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chain constitutes any of the various forms of modern slavery, raise it with your manager or the Leadership Team. 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 part of our supply chain. If you believe that you have suffered any such treatment, you should inform your manager immediately.

Communication and awareness of policy

Training on this policy, and on the risks our business faces from modern slavery in its supply chain, will be provided where needed. 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.

Breaches of this policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Culture

We will:

Update this policy at least once annually in consultation with staff and other stakeholders where necessary.
Involve staff in the implementation of this policy for greater commitment and improved performance.
Provide staff with relevant environmental training.
Work with suppliers, contractors, and subcontractors to improve their environmental performance.
Use local labour and materials where available to reduce CO2 and help the community.

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