Modern slavery and human trafficking

1. About this policy

1.1 This policy is in place to minimise the risks to our business that may arise through non-compliance with the provisions of the Modern Slavery Act 2015.

1.2 You are not expected to carry out a full audit of modern slavery and human trafficking risks in every situation, however, you are expected to be aware of the general risks and to notify management where further analysis or audit may be necessary.

1.3 Monitoring and awareness of modern slavery and human trafficking is an on-going compliance issue that should be reviewed and assessed using a risk-based approach, taking into account each step in the supply chain and considering employment practices risk, geographic location risk, sector risk and any other risks that arise or evolve in the course of business.

1.4 This policy is intended to be an abbreviated general guide for all employees. In the event that a particular area of risk or specific threat is identified, you are expected to raise the matter with management. Management will be able to provide additional materials such as checklists, supplier questionnaires, standard contractual clauses, or appoint an independent expert to review and audit the risk as appropriate where such risk is identified.

1.5 This policy does not form part of any employee’s contract of employment and we may amend it at any time.

2. Where should you look for risk?

2.1 You should consider any supplier, being any individual or company which provides goods or services to the Company. This includes less direct aspects of supply which might include recruitment agents or IT providers.

2.2 You should also consider any client, being any company to whom the Company provides services.

3. Employment risk

3.1 Practices that create risk of modern slavery occur at any point in the employment cycle, including recruitment, employment and termination of employment.

3.2 Factors that arise in the context of the employment relationship include workers being fraudulently charged fees for travel, health checks, or work documentation; workers charged illegal or excessive recruitment fees; underpayment of wages, delayed or withheld wage payments or excessive or illegal wage deductions; workers required to stay in company- or broker-controlled housing and unable to enter or leave the premises freely; working excessive overtime beyond legal or code of conduct limits; workers forced to pay financial

deposits or ‘security’ fees as ‘runaway insurance’; or undocumented migrants threatened with notification of authorities if they leave employment.

4. Geographic risk

4.1 The risk of slavery varies significantly regionally and internationally. You should consider if the relevant country or area has a high prevalence of modern slavery or other human rights violations.

4.2 You should check the Global Slavery Index (http://www.globalslaveryindex.org), which states that the countries with the highest number of people in slavery currently are India, China, Pakistan, Uzbekistan, Russia, Nigeria and the Democratic Republic of Congo. Together, these countries account for almost 65% of the total estimate of 35.8 million people in modern slavery today. If you are proposing to contract with suppliers or clients in these countries in particular, please inform management.

4.3 Another useful resource for understanding which countries may pose a modern slavery and human trafficking risk is Freedom House (https://freedomhouse.org).

5. Sector risk

5.1 Most slavery and human trafficking affects people working at the margins of the formal economy, being those with irregular employment or migration status. Some of these industries typically rely heavily on low-skilled and/or migrant workers.

5.2 Industries that have a particular prevalence of modern slavery include electronics, textiles, clothing and footwear manufacturing, construction and mining. You should consider if the industry your supplier or customer works within is a sector that has a high prevalence of modern slavery.

5.3 The United Nations highlights the main areas of sector risk (http://www.unodc.org). If you have any concerns, please inform management.

6. Relationship risk

6.1 You should consider the value of the contract. As a general rule, the greater the contract value, the greater the risk.

6.2 You should also consider the length of the relationship and if you have any existing information on the risk of modern slavery in relation to the relevant supplier or client. In addition, the media may contain information about whether or not the supplier or client has been the subject of an official report that might indicate there are problems.

1. Basic supplier precautions

1.1 As a general rule, the higher the risk a supplier or client presents, the more likely you will be to want to escalate the issue to management in order to determine if a more in-depth analysis is proportionate and what action to take.

1.2 For lower risk suppliers and clients, you should consider checking if they have:

(a) a public policy on modern slavery that covers not only their own operations, but also contractors and sub-contractors and has governance procedures to ensure compliance;
(b) a signed declaration or contract, committing to enforce the policy on modern slavery; and
(c) contractual obligations that include provision for audits.

1.3 You are not expected to understand any more detail about the Modern Slavery Act 2015 than is set forth or referred to herein.

1.4 If there is anything relating to the Modern Slavery Act 2015 that you are unsure about, you should immediately raise you concerns with management who will decide upon the correct and proportionate course of action.9090