Modern Slavery and Human Trafficking Policy

Introduction

Our organisation is committed to preventing modern slavery and human trafficking in our business operations and supply chains. This policy outlines our approach to identifying, preventing, and mitigating the risks of modern slavery and human trafficking.

Our Commitment

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

Scope

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, third-party representatives, and business partners.

Responsibility 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.

Definition of Modern Slavery

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor, 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.

Due Diligence Processes

We are committed to ensuring transparency in our own business and in our approach to tackling modern slavery throughout our supply chains.

Reporting Concerns

We encourage all employees, customers, and other business partners to report any concerns related to the direct activities or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures without fear of retaliation.

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.

Monitoring and Review

We will review this policy annually and update it as necessary.

This Modern Slavery and Human Trafficking Policy demonstrates our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Approval for this Statement

This statement was approved by:

Graeme Heyes – Director of Sustainable Innovation

Date: 01/07/2024