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 in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we 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.
Responsibility for the 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 and are given adequate training on it through a Safety Media course.
- ‘Modern Slavery Act Interactive’ is made available to all employees.
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.
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 to 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.
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.