Policy statement
Modern slavery is a crime and a 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 to exploit them for personal or commercial gain.
Rodgers Leask Limited has a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships.
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, interns, agents, contractors, external consultants, third-party representatives and business partners.
This policy forms part of an employee’s contract of employment and we may amend it at any time.
Organisational responsibility for this policy
The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those within the Company comply with it.
The Managing Director has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with 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.
Employees are responsible for ensuring that they are aware of the policy and adhere to the requirements of the same.
Our supply chain partners must ensure compliance with this policy and our supplier code of conduct / ethical sourcing policy (RLL-23-XX-PY-G-QM31).
Compliance with the policy
The prevention, detection and reporting of modern slavery in any part of the business or supply chains is the responsibility of all those working for the Company or under our control. Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
To ensure that Rodgers Leask limited undertakes it due diligence, all companies within the Rodgers Leask Limited supply chain are required to complete and submit an approved supplier questionnaire (RLL-20-XX-AU-G-QM06), which is reviewed and scored by the organisation. This document requires the supplier to confirm that they hold and maintain a policy on anti-slavery and that they have not been convicted of any offence relating to child labour or human trafficking. If such a third-party organisation does not have such a policy or that they have been convicted of such an offence, these suppliers shall not be commissioned to undertake work on behalf of Rodgers Leask Limited.
The approved supplier process is repeated on a minimum 3 year repeating basis.
Employees must notify their manager as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future.
Employees are also encouraged to 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.
If it is believed or suspected that breach of this policy has occurred or that it may occur, employees must notify their manager or report it in accordance with our Whistle Blowing Policy as soon as possible.
Communication and awareness of this policy
Training on this policy, and on the risk the business faces from modern slavery in its supply chains, forms part of the induction process for all individuals, and regular training will be provided as necessary through our on-line training portal. Copies of this policy are maintained and accessible to all staff via our employee handbook and the company’s intranet.
A zero-tolerance approach to modern slavery is 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. The Company may terminate its relationship with other individuals and organisations working on our behalf if they breach this policy.