1. POLICY STATEMENT
1.1 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-
1.2 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our company dealings, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our clients, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers and clients will hold their own suppliers to the same high standards.
1.3 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 tear workers, volunteers, interns, agents, contractors, external consultants, third-
1.4 This policy does not form part of any employee’s contract of employment and we may amend it at any time.
2. RESPONSIBILITY FOR THE POLICY
2.1 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.
2.2 The company directors have the primary and day-
2.3 Management at all levels is responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
2.4 You 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 the company directors.
3. COMPLIANCE WITH THE POLICY
3.1 You must ensure that you read, understand and comply with this policy.
3.2 The prevention, detection and reporting of modern slavery in any part of our business, supply chains and clients is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
3.3 You must notify the directors of G-
3.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business, clients or supply chains of any supplier tier at the earliest possible stage.
3.5 If you believe or suspect a breach of this policy has occurred or that it may occur you must notify the directors or report it in accordance with our Whistle blowing Policy as soon as possible.
3.6 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of services or supply chains constitutes any of the various forms of modern slavery, raise it with the directors of G-
3.7 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains or services. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the operations director ‘David Allden’. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure to the finance director ‘Rose Baker’ of G-
4. COMMUNICATION AND AWARENESS OF THIS POLICY
4.1 Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
4.2 Our zero-
5. BREACHES OF THIS POLICY
5.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
5.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
UK Modern Slavery Adult Victim support providers
England and Wales The Salvation Army 0300 303 8151
Scotland Trafficking Awareness Raising Alliance (TARA) 0141 276 7724 Migrant Helpline 07837 937737 or 07789 791 110
Northern Ireland Migrant Help 013 0420 3977 or 07766 668 781 (for male potential victims of human trafficking) Women’s Aid 028 9024 9041 (for female potential victims of human trafficking)
Modern Slavery Helpline The UK Government also provides a 24-
Modern Slavery Act 2015 –
The Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015 –
Transparency in Supply Chains Consultation Document (Feb 2015) and Government Response (July 2015) –
UN Guiding Principles on Business and Human Rights (UNGPS) –www.ohchr.org/Documents/…/GuidingPrinciplesBusinessHR_EN.pdf
Good Business: Implementing the UN Guiding Principles on Business and Human Rights (September 2013) –https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/236901/
UN Global Compact – https://www.unglobalcompact.org/
Walk Free Global Slavery Index –
ILO Resources on Forced Labour, Human Trafficking and Slavery –
Verité eLearning on Supply Chain Accountability – http://www.verite.org/research/elearning
Business and Human Rights Resource Centre –
Ethical Trading Initiative –
Stronger together initiative –
International Tourism Partnership –