This policy applies to all persons working for the Company or on the Company’s behalf in any capacity.

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

The Company strictly prohibits the use of modern slavery and human trafficking in its operations and supply chain. The Company has and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within its organisation or in any of its supply chains. The Company expects that its suppliers will hold their own suppliers to the same high standards.

The Company expects everyone working with it or on its behalf to support and uphold the following measures to safeguard against modern slavery:

  • The Company have a zero-tolerance approach to modern slavery in its organisation and its supply chains.
  • The prevention, detection and reporting of modern slavery in any part of its organisation or supply chain is the responsibility of all those working for the Company or on its behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
  • The Company are committed to engaging with its stakeholders and suppliers to address the risk of modern slavery in its operations and supply chain.
  • The Company takes a risk-based approach to its contracting processes and keep them under review. The Company assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in its contracts with third parties. Using its risked based approach, the Company will also assess the merits of writing to suppliers requiring them to comply with a Code of Conduct, setting out the minimum standards required to combat modern slavery and trafficking.
  • Consistent with its risk-based approach, the Company may require:
    • other third parties engaging with the Company to confirm their compliance with the above principles
    • Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the principles
  • As part of its ongoing risk assessment and due diligence processes, the Company will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with this policy
  • If the Company find that other individuals or organisations working on its behalf have breached this policy The Company will ensure that The Company take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.
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