Anti-Slavery Policy

1. Policy Statement

The Intermediary is unequivocally opposed to slavery and human trafficking in all forms. We are committed to conducting our business responsibly and to maintaining ethical practices that comply with all relevant laws and regulations concerning anti-slavery and human trafficking. This policy outlines our company’s stance on preventing slavery and human trafficking in our operations and supply chain.

2. Scope and Purpose

This policy applies to all individuals employed by and associated with The Intermediary, including permanent and temporary employees, contractors, suppliers, and any other business partners engaged in any capacity with our organisation. This policy sets forth our collective responsibility to uphold our ethical standards and to comply with relevant anti-slavery and human trafficking legislation, specifically the Modern Slavery Act 2015.

3. Responsibilities

  • Management: It is the responsibility of management at all levels to ensure that those under their supervision understand and comply with this policy. They are to act as role models in ethical behaviour and to address any concerns or violations reported by employees or third parties.
  • Employees: All employees are expected to adhere to the principles set out in this policy and to report any suspicions of slavery or human trafficking in our business or supply chains without fear of retaliation.
  • Suppliers and Contractors: All suppliers and contractors working with The Intermediary are required to comply with our anti-slavery policy and must confirm their compliance with these standards and the relevant legislation. Our procurement processes include a specific clause obligating our suppliers to acknowledge and implement this policy.

4. Due Diligence Processes

The Intermediary commits to maintaining a series of due diligence processes to identify, prevent, and mitigate any risks of slavery and human trafficking in our business and supply chain. These include:

  • Risk Assessment: Regularly reviewing the sectors and geographies of our operations and supply chains to assess particular risks of slavery and human trafficking.
  • Supplier Audits: Conducting audits of suppliers, both randomly and based on risk assessment outcomes, to ensure compliance with our policy.
  • Training: Providing training to our employees to help them identify and prevent acts of slavery and human trafficking within our supply chains.

5. Reporting Concerns

Employees and other stakeholders are encouraged to report any concerns or suspicions of slavery or human trafficking in our business or supply chains through our designated channels. This can be done anonymously if desired. We assure that all reports will be treated with confidentiality and investigated promptly and thoroughly.

6. Breaches of the Policy

Breaches of this anti-slavery policy will be regarded as a serious matter and will be dealt with under our disciplinary and grievance procedures. If substantiated, such breaches may lead to a termination of employment for individuals or a cessation of business relations with third parties.

7. Review

This policy will be reviewed annually and updated as necessary to ensure its effectiveness and alignment with the statutory obligations and our commitment to ethical practices.

[Last reviewed 2024]