Anti-Slavery Policy

We strictly prohibit the use of modern slavery and human trafficking in everything we do and throughout our supply chain. We are, 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 or in any of our supply chains. We expect our suppliers will hold their own suppliers to the same high standards.

“Modern slavery” is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. “Human trafficking” is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

Our Commitments

We expect everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

• We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
• We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
• We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked-based approach, we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.
• Consistent with our risk-based approach we may require (a) employment/recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct, and (b) suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to our Code.As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.
• If we find any individual or organisation working on our behalf has breached this policy, we will take appropriate action. This may range from considering the possibility of breaches being remedied and whether we should terminate such relationships.