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 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. This policy will be used to underpin and inform any statement on
slavery and human trafficking that we are required to produce further to the transparency in
supply chain requirements of Section 54 of the Modern Slavery Act 2015
How do we ensure this policy is built into the way we operate?
• We will conduct regular 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, where appropriate, agree how such measures could
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 or director 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 for 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.