Anti -Slavery and Human Trafficking Policy
Modern slavery is a crime and a violation of fundamental human rights. All types of modern slavery
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 ensure modern slavery is not taking place anywhere in our own business or
those we engage with.
We are also committed to ensuring there is transparency in our own business and in our approach to
tackling modern slavery throughout our business relationships, consistent with our disclosure
obligations under the Criminal Law (Human Trafficking) Act 2008, as amended by the Criminal Law
(Human Trafficking) (Amendment) Act 2013. As part of this process, we have undertaken a review of
our supply chain to identify and assess potential risk areas and maintain a register detailing the same.
We expect high standards from all our subcontractors, suppliers and other business partners and have
made this a contractual term in our agreements with significant suppliers wherever possible.
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, interns, 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 of the firm has overall responsibility for ensuring this policy complies with our legal
and ethical obligations, and that all of our people comply with it. The legal department has primary
and day-to-day responsibility for implementing this policy, but the procurement team provide
assistance with reviewing the risk profile of our supply chain to ensure that any procedures
implemented are effective in countering modern slavery.
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 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. Although you should report any concerns
regarding modern slavery and/or human trafficking in any parts of our business or supply chains in
accordance with our whistleblowing policy, you are also encouraged to discuss a specific matter (or
our policy or relevant legislation) with any member of the legal department.
If you are in any doubt about whether a particular act or working conditions in any of our business
relationships may contravene any aspect of this policy then err on the side of caution and report it in
accordance with the whistleblowing policy, or speak to a member of the legal department.
We encourage openness and will support anyone who raises genuine concerns in good faith in
accordance with the firm’s whistleblowing 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 knowledge, or suspicion, that modern slavery is taking place in any part of our business or in any
of our supply chains.
COMMUNICATION AND AWARENESS OF THIS POLICY
Our zero-tolerance approach to modern slavery is communicated to all significant 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 could 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.
