Modern Slavery and Human Trafficking Policy 2020

1. Introduction

1.1. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, agency workers, seconded workers, volunteers, agents, contractors and suppliers.

1.2. The Company strictly prohibits the use of modern slavery and human trafficking in our business and in any of our supply chains. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation.

2. Definitions

2.1. “Modern slavery” is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking.

2.2. “Human trafficking” is where a person arranges or facilitates the travel of another person with a view to that person being exploited.

2.3. Modern slavery is a crime and a violation of fundamental human rights.

3. Compliance

3.1. The Company expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

a. We have a zero-tolerance approach to modern slavery in our organisation and in any of our supply chains.
b. The prevention, detection and reporting of modern slavery in any part of our organisation is the responsibility of all those working for us or on our behalf.
c. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
d. Any suspected breach of this policy should be reported immediately to your Line Manager or a Director.

3.2. We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our organisation.

4. Embedding Principles

4.1 The Company will ensure it undertakes the following activities:

a. Make the relevant staff aware of the Modern Slavery Act 2015 and inform them of the appropriate action to take if they suspect a case of slavery or human trafficking.
b. Ensure that consideration of the modern slavery risks and prevention are added to The Company’s policy review process as an employer and procurer of goods and services.
c. Ensure The Company’s procurement strategies and contract terms and conditions take account of modern slavery and human trafficking.
d. Deliver training sessions to staff procuring goods and services.
e. Review this policy annually.
f. Ensure ongoing engagement and communication between equality and diversity leads, our procurement team and the wider organisation.

5. Breaches

5.1. Any employee who breaches this policy may face disciplinary action, which could result in dismissal for gross misconduct.

We may terminate our relationship with individuals and organisations working on our behalf if they breach this policy.

Further information

If you have any questions or require any additional information regarding this policy,  please contact compliance@fosterfreeman.com