1. POLICY STATEMENT
1.1 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 implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
1.2 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and 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, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
1.3 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, interns, agents, contractors, external consultants, third-party representatives and business partners.
1.4 This policy does not form part of any employee's contract of employment and we may amend it at any time. This policy will be formally reviewed on an annual basis.
2. RESPONSIBILITY FOR THE POLICY
2.1 The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
2.2 The Project Manager in charge of each Project 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.
2.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
2.4 You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to your Project Manager.
3. COMPLIANCE WITH THE POLICY
3.1 You must ensure that you read, understand and comply with this policy.
3.2 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.
3.3 You must notify your Project Manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.
3.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
3.5 If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or as soon as possible.
3.6 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 chains constitutes any of the various forms of modern slavery, raise it with your manager.
3.7 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 of our supply chains. 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 manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally either in terms of this Policy or in terms of our Grievance Policy the A3.1 Procedure (Discipline and Grievance) included in our Health and Safety Policy you would find in our Site records.
4. COMMUNICATION AND AWARENESS OF THIS POLICY
4.1 Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
4.2 Our zero-tolerance approach to modern slavery in our business and supply chains must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
5. BREACHES OF THIS POLICY
5.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct as per The Formal Procedure noted at point 6. The disciplinary procedure can be found in the A3.1 Procedure (Discipline and Grievance) included in our Health and Safety Policy you would find in our Site records.
5.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
6. THE FORMAL PROCEDURE
6.1 General
Each step under this procedure should be taken without any unreasonable delay. The complainant must take all reasonable steps to attend meetings. Meetings with the complainant will be conducted in such a manner as to allow both the complainant and the Employer to state their respective positions. The complainant may if they wish be supported throughout the formal procedure by being accompanied at meetings by a colleague of his/her choice or a trade union representative certified in writing by his/her trade union as having the necessary experience to act as a companion in these circumstances. The companion may at meetings (s)he attends with the complainant, explain the complaint, respond to any views and to sum up but (s)he will not be permitted to answer questions on behalf of the complainant. If a party who would be in attendance at a meeting becomes unable to attend it (s)he or she should contact the Employer immediately so that the Employer may, if appropriate, make alternative arrangements for the meeting. If the original meeting is postponed, another date for the meeting will be given which date will normally be within 5 working days of the original date proposed.
6.2 Stage 1
Complainants will be asked to set out in writing details of the alleged detrimental treatment connected with raising a concern under this Policy, when it is alleged to have occurred, names of any relevant witnesses and details of any action already taken by the complainant about the alleged detrimental treatment. The written details should then be sent to the Project Manager, Senior Management or to a Director.
6.3 Stage 2
After the written details of the complaint are received the complainant and the companion (if any) will be invited to attend a meeting to discuss the circumstances surrounding the complaint in more detail. It is likely that the Employer will require to discuss the circumstances of the complaint with others and to investigate the circumstances so that it can deal appropriately with the complaint. If this is the case the Employer will adjourn the meeting to allow that process to be completed.
6.4 Stage 3
The alleged perpetrator(s) of the detrimental treatment will be informed of the complaint. Depending on the seriousness of the allegation, the alleged perpetrator(s) may be suspended on full pay while the matter is being investigated.
If relevant, as part of the investigative process, witnesses will be interviewed and written statements will be obtained. As far as is reasonable, confidentiality will be maintained throughout the investigative process. However, it may be necessary to disclose certain information so that complaints of detrimental treatment can be fully investigated. The Employer cannot be bound by confidentiality or a request to take no action where it is advised of potential detrimental treatment by another party. As far as is possible those involved in the investigation will however be required to maintain the confidentiality of that process and if that confidentiality is not maintained, appropriate disciplinary action will be taken, which will, in serious cases, include dismissal for gross misconduct.
6.2 Stage 1
Complainants will be asked to set out in writing details of the alleged detrimental treatment connected with raising a concern under this Policy, when it is alleged to have occurred, names of any relevant witnesses and details of any action already taken by the complainant about the alleged detrimental treatment. The written details should then be sent to the Project Manager, Senior Management or to a Director.
6.3 Stage 2
After the written details of the complaint are received the complainant and the companion (if any) will be invited to attend a meeting to discuss the circumstances surrounding the complaint in more detail. It is likely that the Employer will require to discuss the circumstances of the complaint with others and to investigate the circumstances so that it can deal appropriately with the complaint. If this is the case the Employer will adjourn the meeting to allow that process to be completed.
6.4 Stage 3
The alleged perpetrator(s) of the detrimental treatment will be informed of the complaint. Depending on the seriousness of the allegation, the alleged perpetrator(s) may be suspended on full pay while the matter is being investigated.
If relevant, as part of the investigative process, witnesses will be interviewed and written statements will be obtained. As far as is reasonable, confidentiality will be maintained throughout the investigative process. However, it may be necessary to disclose certain information so that complaints of detrimental treatment can be fully investigated. The Employer cannot be bound by confidentiality or a request to take no action where it is advised of potential detrimental treatment by another party. As far as is possible those involved in the investigation will however be required to maintain the confidentiality of that process and if that confidentiality is not maintained, appropriate disciplinary action will be taken, which will, in serious cases, include dismissal for gross misconduct.
6.6 Stage 5
An appeal from stage 4 above should be made as soon as possible after the date of the stage 4 letter. The appeal should be made in writing, to Senior Management or a Director. The employee is requested to set out the reason(s) for the appeal letter.
The employer will then invite the appellant ro appellant to an appeal meeting when the circumstances of the appeal will be discussed in more detail.
6.7 Stage 6
After the appeal meeting he employer will write to the appellant with ists final secision.
There is no Further appeal from this decision.