Introduction

Modern slavery is a crime resulting in despicable abuse of human rights. The Modern Slavery Act (MSA) 2015 came into force as from March 2015 and consolidates slavery and trafficking offenses. It covers four activities:

• Slavery;

• Servitude;

• Forced or compulsory labour;

• Human trafficking.

It ensures that offenses are subject to the toughest asset recovery regime under the Proceeds of Crime Act 2002. The National Crime Agency, the police, and other law enforcement agencies have the powers to bring to justice those engaged in human trafficking and slavery. Modern slavery is a complex and multi-faceted crime, and tackling it requires all partners and staff of Glost Ltd (“the Firm”) to play a part. Protecting the workforce and reputation is vital. The MSA 2015 highlights the important need for businesses, and therefore the Firm, to play a part in tackling slavery.

The Transparency in Supply Chains Clause which came into force in October 2015 requires organizations with a turnover of £36m or more to report on processes and due diligence taken to ensure that their supply chains are slavery-free, and to produce and publish a slavery and human trafficking statement each financial year.

Risk

The principal areas of risk we face, related to slavery and human trafficking, include, but are not limited to the following Business Partners:

• Supply chains;

• Outsourced activities.

The Firm will manage these risks through the procedures set out in this policy.

Responsabilities

The Firm, all employees and members have a responsibility to ensure all colleagues and Business Partners are safeguarded, treated fairly and with dignity. This policy must be observed and any serious concerns which are raised will be dealt with as appropriate and may trigger the Firm’s disciplinary procedures.

The Firm will:

· maintain clear policies and procedures preventing exploitation and human trafficking, protecting our colleagues, Business Partners and our reputation;

· be clear about the recruitment policy;

· check the supply chains;

· make appropriate checks on all employees, recruitment agencies, suppliers, etc.;

· have in place an open and transparent grievance process for all staff.

Supervisors and Line-Managers will:

· listen and be approachable to colleagues;

· respond appropriately if they are told something that might indicate a colleague is in an exploitative situation;

· remain alert to indicators of slavery;

· raise awareness by discussing issues and providing training;

· use their experience and professional judgement to gauge situations.

Clause Example

Modern Slavery. You hereby affirm your compliance with the Modern Slavery Act 2015 and associated guidance. You confirm (a) that you have read, are familiar with and shall not perform an act or omission which is in contravention with, the letter or spirit of the Act; and (b) you carry out regular, meaningful and comprehensive due diligence procedures and have internal policies in place to address any suspected human rights abuse in your business and Group where applicable.

Modern Slavery – The Supplier must:

· comply with all applicable laws, statutes, regulations and codes relating to modern slavery or human trafficking, including the Modern Slavery Act 2015; and

· take reasonable steps to ensure that there is no modern slavery or human trafficking in any part of its business or supply chains.

· The Supplier represents and warrants that the Supplier has not, nor, to its reasonable knowledge, its officers, employees or others associated with it, been convicted or investigated for modern slavery or human trafficking offences.

· The Supplier must promptly report to the Purchaser any actual or suspected slavery or human trafficking in a supply chain in connection with this agreement.

· The Supplier must maintain complete records evidencing its compliance with this clause and grants the Purchaser the right to audit the Supplier for compliance with this