Introduction

We are committed to understanding modern slavery risks and ensuring that there is no modern slavery within our organisation or within our supply chains. This extends to our suppliers, customers and any third party organisation we have dealings with. It is important that all of our employees understand what modern slavery is, understand the warning signs and know where to report suspicions of modern slavery.

What is modern slavery?

It is the forced and compulsory labour of people including human trafficking. The victims are usually overseas workers or vulnerable people from the UK. Usually, the person will be forced to work unlawfully long hours, paid substantially below legal rates and will have had their passports and other personal possessions taken away from them. They are forced to work through mental and/or physical threat and abuse. They are owned and controlled by their employer, dehumanised and treated as a commodity and have a restriction on their freedom of movement and ability to leave the poor working conditions they are trapped in.

Due diligence

We consider ourselves to be a ‘low risk’ business with regard to slavery and human trafficking. However, we foster a culture that encourages the identification and reporting of any such risks within our business. We recruit all our employees either directly or through recruitment agencies who are members of the Recruitment and Employment Confederation. We do not recruit from outside the UK.

Effectiveness in combating slavery and human trafficking

We have zero tolerance to slavery and human trafficking. To ensure that all those in our supply chains comply with our values we are putting in place a supply chain compliance programme that will require our suppliers to confirm that they have a slavery and human trafficking policy in place and that they require the same from their suppliers.

Warning Signs

Below is a list of warning signs to look out for (not an exhaustive list):

• Physical appearance – signs of abuse, looking malnourished or appear withdrawn
• Isolation – Rarely working alone, seemingly under the control or influence of another and rarely interacting with others
• Poor living conditions and suspicions of them living at the same address that they work
• Few personal possessions and wearing the same clothing again and again, sometimes clothing unfit for the work they are undertaking
• Unusual and long working hours with little or no break
• Avoiding eye contact, appearing frightened etc.

Reporting Process

If you suspect anyone you come into contact with during your employment with us, is subject to modern slavery by their employer, you should report this to the Chief People Officer. Every instance will be taken seriously and fully investigated. You will not be victimised for your reporting of a situation and can ask to remain anonymous. You will be fully supported through your reporting of any genuine belief of modern slavery.