Modern Slavery


Modern Slavery & Human Trafficking Policy Statement

Introduction

Modern Slavery is a criminal offence under the Modern Slavery Act 2015. Modern Slavery can occur in various forms, including servitude, forced or 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. This document sets out the Policy with the aim of the prevention of opportunities for Modern Slavery to occur within the Company business or supply chain.

As a Company, we have a zero-tolerance approach to Modern Slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships. We expect all who have, or seek to have, a business relationship with the Company to familiarise themselves with our Policy and to act at all times in a way that is consistent with our anti-slavery values.

Safeguards

The Company is committed to ensuring there is transparency in our business and expect the same level of commitment with regard to the prevention of Modern Slavery from all who we do business with.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith, even if they turn out to be mistaken. We are committed to ensuring that no one suffers detrimental treatment as a result of reporting in good faith, their suspicion that Modern Slavery or human trafficking in whatever form is, or may be, taking place in any part of the Company or in any of our supply chain members’ or business partners’ businesses.

Reporting Process

Any concerns about suspected Modern Slavery associated with the Company or our suppliers, may be raised confidentially by employees via their Line Manager.

In addition, access to a Government 24-hour helpline and website is available to employees and business partners should they prefer this route: modernslavery.co.uk/report-it or 0800 0121 700.

When a Modern Slavery matter is raised internally, the Company will treat all such concerns in a confidential and sensitive manner. The identity of the individual raising the concern may be kept confidential, so long as it does not hinder any investigation.

However, the investigation process may reveal the source of the information and the individual making the disclosure may need to provide a statement as part of the evidence required.

Following the outcome of the investigation process, the Company will inform the relevant statutory body, e.g. Lancashire Police, should Modern Slavery practices be suspected.

Due Diligence, Communication & Awareness

In order to identify and mitigate the risk of Modern Slavery occurring we will: –

  • Include this Policy in our Employee Handbook.
  • Raise awareness amongst our employees.
  • Raise awareness amongst our supply chain during the appointment process.
  • Require supply chain and other business partners to implement their own Modern Slavery prevention procedures.
  • Require confirmation upon appointment that they are aware of this Policy and will abide by it.
  • Encourage the reporting of concerns without detriment to the individual
  • Ensure all Directors and Staff are briefed on the subject.

Responsibility

Ultimate responsibility for the prevention of Modern Slavery rests with the Company’s leadership.  The Managing Director has overall responsibility for ensuring this Policy complies with our legal and ethical obligations.

Review

This Policy does not form part of any employees Contract of Employment and we may amend it at any time. We will continue to review this Policy to ensure it is achieving its aims.

Signed

Andrew Moxham

Managing Director

Date: January 2024