Policy – anti-slavery

Aims of this policy

This policy supports our commitment to limiting the risk of modern slavery occurring within our own business or infiltrating our supply chains or any other business relationship.

The policy applies to all persons working for or on our behalf in any capacity, including employees, directors, officers, agency workers, contractors, consultants, volunteers, and any other third party representative.

We expect all who have, or seek to have a business relationship with the company to familiarise themselves with this policy and to act at all times in a way that is consistent with its values.

We aim to only do business with organisations who fully comply with this policy or those who are taking verifiable steps towards compliance.

What do we mean by modern slavery?

Modern slavery can take many forms. It is a complex and multi-faceted problem.

The MSA covers four key criminal activities:

Slavery: where ownership is exercised over an individual

Servitude: involves the obligation to provide service imposed by coercion

Forced and compulsory labour: all work or service, not voluntarily performed, which is obtained from an individual under the threat of force or penalty

Human trafficking: involves arranging or facilitating the travel of another with a view to exploiting them

Other forms of modern slavery, which we will not tolerate, but are not specifically referenced in the MSA include, but are not limited to:

Child labour: whilst not always illegal in the jurisdiction in which it takes places, child labour involves the employment of children that is exploitative, or is likely to be hazardous to, or interfere with, a child’s education, health (including mental health), physical wellbeing or social development.


  • Employees should be free to choose their employment and leave that employment without hold by financial deposit or personal items.
  • Forced, bonded or involuntary prison labour shall not be used.
  • Support the effective abolition of child labour
  • Comply with the national minimum age for employment, unless a lower local minimum age is permitted under International Labour Organisations (ILO) convention 138
  • Where any child is found to be engaged in or performing child labour, to provide support for that child to enable them to complete, as a minimum, their compulsory education
    (even if they shall cease to be involved in child labour), or an equivalent educational level, as provided for under the UN Covenant on Economic, Social and Cultural Rights. Such support by the supplier should recognise and not prove detrimental to the conditions of the child or those that their work supports.
  • To provide suitable working conditions and terms for staff aged 25 and over and not in the first year of an apprenticeship, at least the National Living Wage must be paid in accordance to the rates detailed at as updated from time to time
  • For staff under 25, at least the right rate of National Minimum Wage must be paid in accordance to the rates detailed at as updated from time to time
  • The above must be paid without discrimination to all employees and all non-statutory deductions must be with the consent of the employee.
  • Working hours must not be excessive. A safe and hygienic environment is provided
  • Any hazardous working, as defined by ILO, should only be carried out by persons aged 18 years or over.
  • Policies and processes must be in place for recording and eliminating
    occurrence/reoccurrence of health and safety related incidents. To treat employees fairly
  • Allow employees the freedom of association to join (but not be forced to join) or be represented by a trade union or similar organisation of their choice
  • Provide a workplace free from discrimination, harassment or victimisation Treat all employees with respect and dignity, and not accept inequality as justifiable of any characteristics listed above, unless statutory conditions require otherwise


All forms of modern slavery have in common the deprivation of a person’s liberty by another in order to exploit them for commercial or personal gain and amount to a violation of an individual’s fundamental human rights.
Tackling modern slavery requires us all to play a part and remain vigilant to the risk in all aspect of our business and business relationships.


How we seek to embed our anti-slavery policy in practice

To underpin our policy commitments, we aim to implement the following measures over the course of the financial year 2019:

  • We will conduct risk assessments to determine which parts of our own business and which of our supply chains are most at risk from modern slavery.
  • Where appropriate, as informed by our risk assessment, we will engage directly with suppliers in respect of our anti-slavery policy in order to gain a proper understanding of the measures they have in place to ensure that modern slavery is not occurring within their own businesses and supply chains, and, where appropriate, agree how such measures should be enhanced.
  • Our contractual documentation will incorporate specific prohibition against slavery or servitude, the use of forced, compulsory or trafficked labour and the use of child labour in line with this policy. We also make provision for our contracted suppliers to hold their own suppliers to the same standards. We also reserve the right to terminate any contractual arrangement if there is breach of this policy.


Responsibility for this policy

The managing director has overall responsibility for this policy and in ensuring that the Company complies with all its legal and ethical obligations.

The compliance officer will have the primary day-to-day responsibility for the implementation of this policy, monitoring its use and ensuring that the appropriate processes and control systems are in place, and amended as appropriate, to ensure it can operate effectively.

Communication and employee awareness training
The compliance officer will ensure that relevant staff receive adequate training on this policy and any supporting processes applicable to their role.

Breaches of this policy

Any breaches of this policy will be taken seriously and dealt with on a case by case basis.

The breach of this policy by an employee, director or officer of the company may lead to disciplinary action being taken in accordance with our disciplinary procedure. Serious breaches may be regarded as gross misconduct and may lead to immediate dismissal further to our disciplinary procedure.

Everybody to who whom this policy applies will be expected to co-operate to the fullest extent possible in any investigation into suspected breaches of this policy or any related processes or procedures.

If any part of this policy is unclear, clarification should be sought from the compliance officer.

Status of this policy

This policy does not give contractual rights to company employees and we reserve the right to alter any of its terms at any time. We will notify applicable parties in writing of any changes which may affect them.


DOC NO: 811-0902UK
DCO#: 00054UK REV: A EFF DATE: 24/05/2018