Modern Slavery is a crime and a gross violation of fundamental human rights.  It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

It is our approach to comply with all laws, rules and regulations relevant to our business, in all countries where we operate, specifically England.  We have a zero-tolerance approach to modern slavery and we are committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business and in our supply chains.  

This policy applies to all members, employees, agents, consultants, suppliers or other people or bodies associated with the business, wherever in the world they operate.  Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.   All staff involved with procurement or managing a supply chain must complete the modern slavery training.

Our zero-tolerance approach must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced in our approach as appropriate thereafter.  We may terminate our relationship with individuals and organisations working on our behalf, if they do not comply with this policy.

Although the overall responsibility for ensuring the policy complies with all our legal and ethical obligations lies with the Management board, day to day responsibility will be held by the Risk and Compliance Director.  The Risk and Compliance Director will deal with any queries on the policy and will monitor the internal control systems.  Any suggestions and queries on the policy are encouraged and should be directed to the Risk and Compliance Director.

Responsibility for reporting incidents of slavery

The detection and reporting of slavery is the responsibility of us all.  You should raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.  Suitable channels of communication by which you can report confidentially any suspicion of slavery will be maintained through the firm’s whistleblowing policy.
Any person reporting, in good faith, their suspicion of modern slavery, will not suffer detrimental treatment as a result.  In the event an individual believes they have suffered detrimental treatment as a result should refer to the Complaints and Grievances policy.

October 2017