Modern Day Slavery Policy.

1. Policy statement

1.1 Modern slavery is a  crime and a violation of fundamental human rights. It takes various forms,  such as slavery, servitude, forced and 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.  We have a zero-tolerance approach to modern slavery and we are committed to  acting ethically and with integrity in all our business dealings and  relationships and to implementing and enforcing effective systems and  controls to ensure modern slavery is not taking place anywhere in our own  business or in any of our supply chains. 

1.2 We are also committed to ensuring there is transparency in our own  business and in our approach to tackling modern slavery throughout our supply  chains, consistent with our disclosure obligations under the Modern Slavery  Act 2015. We expect the same high standards from all of our contractors,  suppliers and other business partners, and as part of our contracting  processes, we include specific prohibitions against the use of forced,  compulsory or trafficked labour, or anyone held in slavery or servitude,  whether adults or children, and we expect that our suppliers will hold their  own suppliers to the same high standards.  

1.3 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. 

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

2. Responsibility  for the policy

2.1 The 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. 

2.2 The Directors has primary and day-to-day responsibility for implementing  this policy, monitoring its use and effectiveness, dealing with any queries  about it, and auditing internal control systems and procedures to ensure they  are effective in countering modern slavery. 

2.3 Line managers 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. 

2.4 You are invited to comment on this policy and suggest ways in which it  might be improved. Comments, suggestions and queries are encouraged and  should be addressed to the Directors. 

3. Compliance with  the policy

3.1 You must ensure that  you read, understand and comply with this policy. 

3.2 The prevention, detection and reporting of modern slavery in any part of  our business or supply chains is the responsibility of all those working for  us or under our control.

You are required to avoid any activity that might  lead to, or suggest, a breach of this policy. 

3.3 You must notify your manager as soon as possible if you believe or  suspect that a conflict with this policy has occurred, or may occur in the  future. 

3.4 You are encouraged to raise concerns about any issue or suspicion of  modern slavery in any parts of our business or supply chains of any supplier  tier at the earliest possible stage. 

3.5 If you believe or suspect a breach of this policy has occurred or that it  may occur you must notify your manager or report it in accordance with our  Whistleblowing Policy as soon as possible. 

3.6 If you are unsure about whether a particular act, the treatment of  workers more generally, or their working conditions within any tier of our  supply chains constitutes any of the various forms of modern slavery, raise  it with your manager or a Director. 

3.7 We aim to encourage openness and will support anyone who raises genuine  concerns in good faith under this policy, even if they turn out to be  mistaken. We are committed to ensuring no one suffers any detrimental  treatment as a result of reporting in good faith their suspicion that modern  slavery of whatever form is or may be taking place in any part of our own  business or in any of our supply chains. Detrimental treatment includes  dismissal, disciplinary action, threats or other unfavourable treatment connected  with raising a concern. If you believe that you have suffered any such  treatment, you should inform the Head of Procurement immediately. If the  matter is not remedied, and you are an employee, you should raise it formally  using our Grievance Procedure. 

4. Communication  and awareness of this policy

4.1 Training on this  policy, and on the risk our business faces from modern slavery in its supply  chains, forms part of the induction process for all individuals who work for  us, and regular training will be provided as necessary. 

4.2 Our zero-tolerance approach to modern slavery must be communicated to all  suppliers, contractors and business partners at the outset of our business  relationship with them and reinforced as appropriate thereafter. 

5. Breaches of this policy 

5.1 Any employee who breaches this policy will face disciplinary action,  which could result in dismissal for misconduct or gross misconduct. 

5.2 We may terminate our relationship with other individuals and  organisations working on our behalf if they breach this policy.