Anti-slavery, human trafficking and child labour  policy 

Policy Statement 

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-tolerance approach to modern slavery and we are  committed to acting ethically and with integrity in all our business dealings  and relationships and to implementing and enforcing effective systems and  controls to ensure modern slavery is not taking place anywhere in our own  business or in any of our supply chains. 

We are also committed to ensuring there is transparency in our own business  and in our approach to tackling modern slavery throughout our supply chains,  consistent with our disclosure obligations under the Modern Slavery Act 2015. 

We expect the same high standards from all of our contractors, 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 will hold their own suppliers to the same high  standards. 

This policy does not form part of any employee’s contract of employment and  we may amend it at any time. 

 

Who must comply with this policy?

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 workers, volunteers, interns, agents, contractors, external  consultants, supplier, service providers, third-party representatives and  business partners. 

 

Compliance with the policy 

You must ensure that you read, understand and comply with this policy. 

The prevention, detection and reporting of modern slavery in any part of our  business or supply chains 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. 

You must notify Anita Schlesinger, Director as soon as possible if you believe or  suspect that a conflict with this policy has occurred, or may occur in the  future. 

You are encouraged to raise concerns about any issue or suspicion of modern  slavery in any parts of our business or supply chains of any supplier tier at the  earliest possible stage. 

If you believe or suspect a breach of this policy has occurred or that it may  occur you must notify Anita Schlesinger, Director. 

If you are unsure about whether a particular act, the treatment of workers  more generally, or their working conditions within any tier of our supply chains  constitutes any of the various forms of modern slavery, raise it with Anita  Schlesinger, Director. 

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. 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 Anita Schlesinger immediately. If the matter is not  remedied, and you are an employee, you should raise it formally using our  grievance procedure.

 

How to raise a concern 

You are encouraged to raise concerns about any issue or suspicion of  malpractice at the earliest possible stage. If you are aware of, or you believe  or suspect that any breach of this policy has occurred or may occur, you must  notify Isac Weiss. 

 

Communication and awareness of this  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 in our business and supply  chains must be communicated to all suppliers, contractors and business  partners at the outset of our business relationship with them and reinforced as  appropriate thereafter. 

 

Breaches of this policy 

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

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

 

Who is responsible for this 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. The board of directors has approved the policy. All  such approaches will be treated in confidence. 

Isac Weiss, manager has primary and day-to-day responsibility for  implementing this policy, and for monitoring its use and effectiveness and  dealing with any queries on its interpretation.

Management at all levels are responsible for ensuring those reporting to them  are made aware of and understand this policy and are given adequate and  regular training on it.