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Modern slavery

All new and existing colleagues are subject to prescribed right to work checks that help us make sure we do not employ illegal workers, thereby complying with the Immigration, Asylum and Nationality Act 2006. Additionally, any third- party organisations who are contracted to work on our behalf are required to apply a similar procedure for their team too.

We will continue to update our Modern Slavery Policy to reflect updated procedures. This policy, last updated in March 2024, highlights our commitment to acting ethically and with integrity in all our business relationships. It also implements and enforces effective systems and controls to provide assurance that slavery and human trafficking does not take place anywhere in our supply chains.

We operate a Code of Conduct for our colleagues. This requires them to uphold our high standards of integrity, honesty and transparency in everything they do. Colleagues must report any possible breach of the Code of Conduct to one of: their line manager; our HR team; a member of our Senior Management Team.

Our Modern Slavery Policy takes a co-ordinated and victim-centred approach, making clear that safeguarding is everyone’s responsibility; and for services to be effective they need to be based on a clear understanding of the needs and views of people impacted by modern slavery.

Anyone can witness or become aware of information suggesting that modern slavery is occurring. We encourage our colleagues to be vigilant on behalf of those unable to protect themselves. And regardless of how the concern is identified, everyone should understand what to do, and where to go to get help and advice.

We encourage our colleagues to report any slavery, human trafficking or other ethical concerns.

We remind our colleagues to look out for, amongst others, the following potential signs of modern slavery. People may:

  • appear to be under the control of someone else and reluctant to interact with others;

  • not have personal identification on them;

  • have few personal belongings, wear the same clothes every day or wear unsuitable clothes for work;

  • not be able to move around freely;

  • be reluctant to talk to strangers or the authorities.

Speaking up – our whistleblowing strategy

As a responsible business, we comply with all applicable laws and regulations and behave with honesty and integrity in how we operate. We have put in place standards and policies which make sure we take the necessary and appropriate steps in accordance with legal and regulatory requirements and conduct our business in a professional and ethical manner. However, the standards we set ourselves can only be achieved and maintained through the conduct of our team.

It is the obligation of all our colleagues to conduct themselves in a manner that maintains these standards and, if necessary, to draw attention to any malpractice or unlawful conduct which they suspect is taking place at work so that it can be investigated and addressed.

We want to create the climate and the opportunities for everyone to do the right thing and speak out confidentially about any genuinely held concerns about actions or decisions that they think are wrong. The facts will be investigated fairly, thoroughly and promptly.

  • We have an internal whistleblowing process in place which allows anyone to raise any concerns they may have regarding modern slavery, suspicious activity, unethical conduct or illegal actions – either within our business or in dealings with third parties by: reporting them to their line manager;

  • speaking to a HR Manager (or Trades Union representative if relevant);

  • contacting their safety representative if it concerns a health and safety issue.

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