1.PURPOSE
The Company is committed to a work environment that is free from human trafficking, forced labour and unlawful child labour (“human trafficking and slavery”). We strongly believe that we are responsible for promoting ethical and lawful employment practices. These practices are also required to be followed by our suppliers and subcontractors. This policy also complies with the Modern Slavery Act 2015.
2.SCOPE
This policy covers all employees of the Company.
3.DEFINITIONS
- Human Trafficking: the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation.
- Forced Labour: all work or service, not voluntarily performed, that is obtained from an individual under the threat of force or penalty.
- Harmful Child labour: consists of the employment of children that is economically exploitative, or is likely to be hazardous to, or interfere with, the child’s education, or to be harmful to the child’s health, or physical, mental, spiritual, moral, or social development.
4.POLICY
The Company will not tolerate the use of unlawful child labour or forced labour in the services it provides and will not accept products or services from Suppliers that employ or utilise child labour or forced labour in any manner. These crimes exist in countries throughout the world. This Policy is to define how the Company will make efforts to eradicate human trafficking and slavery from not only within its organisation but also from our supply chains.
5.ORGANISATIONAL STRUCTURE AND SUPPLY CHAINS
This policy covers the business activities of the Company.
The company currently operates in the following countries:
- United Kingdom
6.HIGH RISK ACTIVITIES
The following activities are considered to be at high risk of modern slavery or human trafficking:
- None
7.DUE DILIGENCE
The company undertakes due diligence in relation to Slavery and Human Trafficking. The company’s due diligence process includes:
- Only purchasing parts from UK suppliers who comply with legislation
- Training of staff on company process of purchasing
8.RESPONSIBILITIES
Responsibility for the Company’s anti-slavery initiatives is as follows:
- Policies: A Director is responsible for creating and reviewing policies. The process by which policies are developed is to evaluate and establish the needs of the business whilst considering all relevant Human Rights and ethical implications.
- Risk assessments: A Director is responsible for risk assessments in respect of human rights and modern slavery.
- Due diligence: A Director is responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking.
- A Director will review this Policy on an annual basis.
- Suppliers must be able to demonstrate compliance with this Policy at the request and satisfaction of the Company.
- Suppliers who engage in human trafficking and slavery will have their supply agreements terminated.
- If a Supplier to the Company is found to contravene this policy, the Company will take prompt, remedial measures to address the issue.