a)  Policy Statement

We are committed to conducting our business in an ethical, legal and socially responsible way and are committed to ensuring systems are put in place to prevent slavery, human trafficking and labour exploitation from occurring in any part of our business or supply chains.

We aim to ensure that we:

• will treat people fairly and not exploit or expose them to unsafe working conditions
• will not knowingly do business with any partners or suppliers who are in breach of applicable legislation and regulations, including health, safety, environmental, human rights and employment laws
• implement and enforce effective systems and controls to ensure modern slavery, forced and child labour is not taking place anywhere in our business or our supply chains
• act ethically and with integrity in all our business dealings and relationships

b)  Responsibilities

The Directors have overall responsibility for ensuring this Policy complies with our legal and ethical obligations and that all those under our control comply with it. Directors also monitor its use and effectiveness, dealing with any queries about it and auditing internal control systems and procedures to ensure they are effective in maintaining ethical practices and countering modern slavery.

The prevention, detection and reporting of modern slavery in any part of our Company or our supply chains is the responsibility of all those working for us or under our control. They are required to avoid any activity that might lead to, or suggest, a breach of this Policy.

All employees and workers have a responsibility to report any concerns regarding illegal activity, non-ethical behaviour, modern slavery, labour exploitation and human trafficking. The Directors have a responsibility to act upon such concerns in an efficient, timely, effective and fair way.

c)  Definitions

Ethical conduct means compliance with all laws, rules and regulations regarding the Company’s business and interacting fairly, safely and responsibly with all employees, workers, contractors, suppliers and clients.

Modern slavery is a crime and violation of fundamental human rights. It encompasses slavery, servitude, forced and compulsory labour, human trafficking and any actions that result in the deprivation of a person’s free will by another in order to exploit them for personal or commercial gain. 

Forced Labour refers to work that is performed involuntarily and under the menace of any penalty. It refers to situations in which individuals are coerced to work through the use of violence or intimidation, or by more subtle means such as manipulated debt, retention of identity papers or threats of denunciation to immigration authorities.

Child Labour refers to the exploitation of children (ie those aged under the minimum school leaving age) through any form of work that deprives children of their childhood, interferes with their ability to attend regular school, and is mentally, physically, socially and/or morally harmful.

d)  Methodology

The Policy applies to all people working for us or on our behalf in any capacity, including employees and workers at all levels, as well as contractors.

We are particularly vigilant during recruitment processes to ensure no individual or organisation sources and supplies workers without first confirming that workers are not being charged a work finding fee.

The Directors review this Policy annually, or in response to any major business or organisational change, legislative change or any breach or concerns regarding the Company’s ethical, legal or social responsibilities.

Employees and workers are encouraged to identify and report any potential breaches of the Policy and will be provided with whistleblowing protection if required. Any employee or worker who breaches this Policy will face disciplinary action, which could result in dismissal for gross misconduct.

The Company’s ethical standards and zero-tolerance approach to modern slavery is communicated to all suppliers, contractors and clients at the outset of any business relationships with them and reinforced as appropriate thereafter. Any breaches of this Policy are likely to lead to terminations of contract with individuals, businesses or partnerships. Where applicable, information will be passed on to the police for further investigations and/or prosecution.