Statement

Modern slavery and human trafficking are violations of fundamental human rights. They may take various forms including slavery, bonded, and forced labour, sex trafficking, child labour and domestic servitude. These criminal activities all deprive people of liberty in exploiting them for personal or commercial gain.

1. The purpose of our Company is to supply.
2. We are committed to ethical principles and require all employees to comply with the employment legislation and supply chain management legislation in the countries within which we operate.
3. We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business. This policy applies to all persons who act on our behalf in any capacity, including employees at all levels, CEO, directors, consultants, contractors, agency workers, volunteers, interns, business partners and our supply chain.

We are committed to ensuring transparency in our own Company and in our approach to tackling modern slavery throughout our supply chains.

Supply Chain Management

1. We will not support or deal with any business which is known to be involved in slavery or human trafficking.
2. As part of our due diligence procedure, prior to approving a new supplier, we will review the controls which they undertake to eliminate modern slavery and human trafficking, particularly regarding goods imported from outside the UK and EU which are potentially more at risk of involving slavery and human trafficking.

Responsibility

1. Lynn Ford has been briefed on this subject and takes responsibility for implementing this policy. This statement has been fully approved by all members of the board.
2. Managers at all levels are responsible for ensuring that all those who report to them understand and comply with this policy.

Employees at all levels are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to Lynn Ford (HR).

Compliance

1. All employees must read, understand and comply with this policy.
2. All employees must avoid any breaches of this policy. The prevention, detection and reporting of modern slavery in any part of our Company or supply chains is the responsibility of all those working for us or under our control. Employees must avoid any activity that breaches this policy
3. All employees must report to their manager at the earliest opportunity if they suspect or believe there has been a breach of this policy or that a breach may occur in the future.
4. Employees are reminded that there are systems in place to encourage the reporting of concerns and to protect whistleblowers.

Communication

1. We will provide training about the risks of modern slavery and human trafficking to maintain a high level of understanding of this issue in our workforce.
2. Our zero-tolerance approach to modern slavery will be clearly communicated to all suppliers, contractors and business partners when we commence a business relationship with them and reinforced in our subsequent communications with them.

Breaches of Policy

1. Any employee who breaches this policy will face disciplinary action which could result in dismissal for misconduct or gross misconduct.
2. We will terminate relationships with suppliers, individuals or business partners working on our behalf if this policy is breached.

Review

This policy will be reviewed annually, to ensure that it remains up to date and reflects the needs and practices of the organisation. The policy may also be reviewed if legislation changes or if monitoring information suggests that policy or practices should be altered.