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Anti-Slavery and Human Trafficking Policy

v1.2 May 2018

Introduction

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Victims are coerced, deceived and/or forced against their free will into providing work or services. Human trafficking is a practice where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery and human trafficking are crimes and a violation of fundamental human rights.

Exclaimer prohibits the practice of modern slavery and/or human trafficking in our operations. We are committed to implementing systems and controls aimed at ensuring that modern slavery and/or human trafficking are not taking place anywhere within our organisation.

Scope

This policy applies to all persons working for Exclaimer, including employees at all levels, directors, officers, agency workers, third-party representatives and business partners.

This policy does not form part of any employee's contract of employment and we may amend it at any time. All workers must ensure that they read, understand and comply with this policy.

Policy Statement

We are committed as an organisation to undertaking the following measures to safeguard against modern slavery and human trafficking:

  • We have a zero-tolerance approach to modern slavery and human trafficking in our organisation and within our supply chain. The prevention, detection and reporting of modern slavery and human trafficking in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf.
  • We are committed to gaining a clearer understanding of how modern slavery and human trafficking operates in different contexts, of who is affected and how, and of the risks of modern slavery and human trafficking within our profession.
  • We are committed to having a clear and transparent Modern Slavery Statement, which is reviewed regularly and communicated to our employees, which sets out the steps taken to prevent modern slavery and human trafficking in our business, our brand and our supply chain.
  • Our recruitment procedures will require employment and recruitment agencies and other third parties supplying workers to our organisation to comply with our Code of Conduct. Suppliers engaging workers through a third party are also required to obtain such third parties’ agreement to adhere to our Code of Conduct.
  • Our commitment in respect of those working for us is:

To ensure that our workers do not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.

To ensure that our employees understand and adhere to this policy and are trained on them as appropriate. Non-compliance with those policies may result in disciplinary action. Our policies are reviewed on a regular basis and re-communicated to all staff regularly.

  • Our commitment in respect of our members, suppliers and contractors is:

To engage with our members, contractors and suppliers to address the risk of modern slavery and human trafficking in our operations.

  • To audit contractors and suppliers, based on risk, for their compliance with our Code of Conduct. We aim to work with contractors and suppliers to remediate incidents of non-compliance and may terminate the relationship in response to gross, persistent or deliberate failures.

In more detail

  • Employees must notify their manager or otherwise report a concern in accordance with the Whistleblowing Policy as soon as possible if they have any reason to believe that modern slavery and/or human trafficking of any form is or may be taking place in any part of our own business, or may occur in the future, or have any concerns or suspicions relating to compliance with this policy.
  • We aim to encourage openness and will support anyone who raises genuine concerns 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 their genuine suspicion that modern slavery and/or human trafficking of any form is or may be taking place in any part of our own business or may occur in the future. 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 your Line Manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Policy.

Further questions

If you have further questions about Exclaimer’s policies or service options that may assist you with your compliance needs, please liaise with your Exclaimer representative or email [email protected]

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