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.
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 and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.
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, agents, contractors, external consultants, third-party representatives and business partners. All work must be carried out voluntarily.
Workers must have the right to terminate their employment freely, as appropriate following a reasonable period of notice in accordance with applicable laws and collective agreements, and without the imposition of any improper penalties.
Workers shall not be mentally or physically coerced to provide their labour.
Workers shall not be subject to forced, prison, bonded, indentured, slave, trafficked or compulsory labour in any form, including forced overtime.
If it is necessary to recruit workers via a third party such as an employment agency, then only reputable agencies shall be used. Fees or costs associated with the recruitment of workers (including, but not limited to fees related to work visas, travel costs and document processing costs) shall not be charged to workers whether directly or indirectly. Similarly, workers shall not be required to make payments which have the intent or effect of creating workplace slavery, including security payments, or be required to repay debt through work.
Workers shall not have their identity documents or travel permits, passports or official documents or any other valuable items confiscated or withheld as a condition of employment and the withholding of property shall not be used directly or indirectly to restrict workers’ freedoms or create workplace slavery.
There shall be no child labour. Nobody shall be employed under the minimum age. Subject to the overriding prohibition on the use of child labour, if workers under the age of 18 are employed then particular care shall be taken as to the duties that they carry out and the conditions in which they are required to work to ensure that they come to no physical, mental or other harm as a direct result of their work or working conditions.
Workers, their families and those closely associated with them shall not be subject to harsh or inhumane treatment including but not limited to physical punishment, physical, psychological or sexual violence or coercion, verbal abuse, harassment or intimidation. Migrant workers, their families and those closely associated with them should not be subject to discrimination due to their nationality.
Workers shall be free to file grievances to their employers about employer’s treatment of them and workers shall not suffer detriment, retaliation or victimisation for having raised a grievance.
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 under our control comply with it.
The managing director has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and dealing with any queries about it.
COMPLIANCE WITH THE POLICY
All staff must ensure that they read, understand and comply with this policy.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control
BREACHES OF THIS POLICY
Any person concerned about the breach of this Code of Conduct or our Anti-Slavery and Human Trafficking Policy may report their concerns to the company CEO, whose contact details appear below. Individuals with concerns are encouraged to provide their name and contact details so that the issues they raise can be investigated thoroughly. However, we recognise that is some circumstances an individual will only be prepared to raise their concerns on an anonymous basis and we commit to investigate anonymous allegations as thoroughly as possible to take the necessary remedial action.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.