English Chain Modern Slavery Statement
POLICY STATEMENT
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 implement and enforce effective systems and
controls to ensure modern slavery is not taking place anywhere in our own
business or our supply chain.
We are also committed to ensuring there is transparency in our own
business and in our approach to tackling modern slavery throughout our supply
chain. We expect the same high standards from all of our contractors, suppliers
and other business partners. 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, and we expect that our
suppliers will hold their own suppliers to the same high standards.
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, agents, contractors, external
consultants, 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.
RESPONSIBILITY FOR THE POLICY
The management team has overall responsibility for ensuring this
policy complies with our legal and ethical obligations, and that all those
under our control comply with it
The Managing Director 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.
Management at all levels are responsible for ensuring those
reporting to them understand and comply with this policy and are given any
required training.
COMPLIANCE WITH THE POLICY
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 or under our control. You are required to avoid any activity that might
lead to, or suggest, a breach of this policy.
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.
You are encouraged to raise concerns about any issue of suspicion
of modern slavery in any parts of our business or the supply chains of any
supplier tier at the earliest possible stage.
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 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 chain constitutes any of the various forms of modern slavery, raise it
with your manager.
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 part of our supply chain. If you believe that you have suffered any such
treatment, you should inform your manager immediately.
COMMUNICATION AND AWARENESS OF POLICY
Training on this policy, and on the risk our business faces from
modern slavery in its supply chain will be given where needed.
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.
BREACHES OF THIS POLICY
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.
01/10/21 CDT