1.Overview

This policy applies to all persons working for the Company or on its behalf in any capacity, including employees at all levels, directors, officers, bank and agency workers, volunteers, agents, contractors, external consultants, third-party representatives, and business partners.

2. What is modern slavery?

Modern slavery is the illegal trade of human beings for the purpose of commercial sexual exploitation or reproductive slavery, servitude, forced or compulsory labour, human trafficking or a modern-day form of slavery.

Slavery is the behaviour which deprives the victim of his or her freedom as though the offender owns the person;
Servitude is the obligation to provide services that is imposed by the use of coercion;
Forced or compulsory labour is a service which is exacted from a person under the menace of any penalty, where the person has not offered themselves voluntarily and involves coercion, which may be direct threats of violence or more subtle forms of compulsion; and
Human trafficking arises when a person arranges or facilitates the travel of another person with a view to that person being exploited even where the victim consents to the travel.

Anyone can become a victim of modern slavery. There are several ways you might encounter a victim of modern slavery, these include:

a person may tell you about their experience;
you detect signs that suggest a person may have been a victim of modern slavery;
through a third party.

Signs to spot potential victims include:

is the person in possession of their legal documents (passport identification and their own bank account details) or are these being held by someone else? Victims will often be forced to use false or forged identity documents.
do they appear under the control or influence of others and rarely interact with colleagues?
are there a group of colleagues who have their wages paid into the same bank account? Are they having wages taken off them for accommodation, food or to repay supposed debt?
is the person afraid of the authorities (police, immigration, tax office)?
are there a number of people who are listed as living at the same address? This may indicate high shared occupancy, often a factor for those being exploited.
do they appear to be moving location frequently? This may indicate that they are under another's control.
do agency staff have a written contract of employment with their agency? Is there any suspicion that they have had to pay any direct or indirect fees to obtain work?
do they give a vague and inconsistent information about their medical history or about how they sustained an injury?

3. Your responsibilities

Slavery is the behaviour which deprives the victim of his or her freedom as though the offender owns the person;
Servitude is the obligation to provide services that is imposed by the use of coercion;
Forced or compulsory labour is a service which is exacted from a person under the menace of any penalty, where the person has not offered themselves voluntarily and involves coercion, which may be direct threats of violence or more subtle forms of compulsion; and
Human trafficking arises when a person arranges or facilitates the travel of another person with a view to that person being exploited even where the victim consents to the travel.

Anyone can become a victim of modern slavery. There are several ways you might encounter a victim of modern slavery, these include:

a person may tell you about their experience;
you detect signs that suggest a person may have been a victim of modern slavery;
through a third party.

Signs to spot potential victims include:

is the person in possession of their legal documents (passport identification and their own bank account details) or are these being held by someone else? Victims will often be forced to use false or forged identity documents.
do they appear under the control or influence of others and rarely interact with colleagues?
are there a group of colleagues who have their wages paid into the same bank account? Are they having wages taken off them for accommodation, food or to repay supposed debt?
is the person afraid of the authorities (police, immigration, tax office)?
are there a number of people who are listed as living at the same address? This may indicate high shared occupancy, often a factor for those being exploited.
do they appear to be moving location frequently? This may indicate that they are under another's control.
do agency staff have a written contract of employment with their agency? Is there any suspicion that they have had to pay any direct or indirect fees to obtain work?
do they give a vague and inconsistent information about their medical history or about how they sustained an injury?

4. How to raise a concern

You are encouraged to raise concerns about any issue or suspicion of modern slavery in the Company or in its supply chains at the earliest possible stage.

you must report it to your line manager or report it by following the procedure set out in our Whistleblowing Policy as soon as possible.

If you are unsure whether a suspicion indicates modern slavery, or if you have any other queries, these should be raised with your line manager in the first instance.

In all cases, trust and act on your instinct that something is not quite right. It is usually a combination of triggers, an inconsistent story and a pattern of symptoms that may cause you to suspect modern slavery.

If you think that someone you work with at the Company or at a third party may be a victim of modern slavery, in addition to the above, you can call the modern slavery helpline on 0800 0121 700 and talk through your concerns or visit www.modernslavery.co.uk which provides more information on the types of slavery, the signs to spot and the appropriate referral processes for victims.

Colleagues who raise concerns are sometimes worried about possible repercussions. 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.

5. Who is responsible 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.

Management at all levels are 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.

6. Awareness of the policy

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.

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

7. Monitoring and review

The Board of Directors will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible.

All colleagues are responsible for the success of this policy and should ensure they use it to raise concerns of any suspected modern slavery.

8.Monitoring and review