ANTI-SLAVERY and HUMAN TRAFFICKING

INTRODUCTION

1. Purpose and Objectives

This policy reflects our approach to introduce, review and improve our practices to ensure there is no modern slavery or human trafficking in any part of our business or supply chain.  This policy has been introduced in conjunction with our Modern Slavery and Human Trafficking Statement to comply with our obligations under the Modern Slavery Act 2015.

2. Status of this policy

This policy is in force from 4 December 2017.  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 (“SMD Workers”).  This policy also applies to all of our suppliers across all of our supply chains (“SMD Suppliers”).

This policy does not form part of any employee’s contract of employment and does not give contractual rights to individual employees.  We reserve the right to alter this policy at any time.  Changes shall be advised internally by email and the company Intranet. Revised versions of the policy shall also be published on our website so suppliers should check periodically for the latest version.

POLICY STATEMENT

3. Modern Slavery and Human Trafficking

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 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.

4. Combatting Modern Slavery and Human Trafficking

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.

We have also introduced new due diligence procedures to determine what policies and measures our suppliers have put in place to address modern slavery and human trafficking, and have reviewed our internal processes and procedures to capture and assess results from this due diligence accordingly.  We expect that our suppliers will hold their own suppliers to the same high standards.

RESPONSIBILITY FOR THE POLICY

5. Overall Responsibility

The board of 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.

6. Supervisory Responsibility

The Chief Financial Officer has supervisory responsibility to ensure this policy is implemented across the business and supply chain and provide adequate resources to facilitate this.

7. Day-to-Day Responsibility

For SMD Workers our HR Manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it and ensuring actions taken are effective in countering modern slavery.

Management 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.

For SMD Suppliers our Operations Manager has primary and day-to-day responsibility for implementing this policy across our supply chain, monitoring its use and effectiveness, dealing with any queries about it and ensuring actions taken are effective in countering modern slavery.

COMPLIANCE WITH THIS POLICY

8. Your Actions

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

The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us, under our control or supplying to us.  You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

As an SMD Worker, you must notify the HR Manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.  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.

As an SMD Supplier, you must notify the Operations Manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.  You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of your business or supply chains of any tier at the earliest possible stage.

9. Suspected Breach

If you are an SMD Worker and you believe or suspect a breach of this policy has occurred or that it may occur, you must notify the HR Manager or CFO as soon as possible.  If you are an SMD Supplier and you believe or suspect a breach of this policy has occurred or that it may occur, you must notify the Operations Manager or the CFO as soon as possible.

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 the HR Manager or Operations Manager as appropriate.

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 SMD Worker 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 HR Manager immediately.  If the matter is not remedied, and you are an employee, you should raise it formally using our Disciplinary and Grievance Policy, which can be found on SharePoint.

COMMUNICATION AND AWARENESS OF THIS POLICY

10. Communication to Current Staff

This policy has been communicated to all SMD Workers by a blanket email and covering note.  All SMD Workers have been asked to read and familiarise themselves with this policy and are encouraged to direct any questions they may have to the HR Manager.

11. Staff Inductions

Communication of this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all new individuals who start work for us.

12. Training

Training will be provided as necessary to those SMD Workers directly involved in dealing with suppliers and our supply chain.

13. Communication to Suppliers

Reference to this policy is made in our current standard terms and conditions of purchase and standard agency agreement templates.  This policy is available on our website.  In addition, our commitment to addressing the issue of modern slavery in our business and supply chains must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

BREACHES OF THIS POLICY

14. Consequences of Breach

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

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