Ethical and modern slavery policy

1.0 Policy statement

1.1 This Policy sets out the Groups zero-tolerance approach to modern slavery.  The Group is committed to acting ethically and with integrity in all its business dealings and relationships and  implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its UK business operations or in any of the Groups supply chains.

1.2 Modern slavery is a crime and a violation of fundamental human rights. The Group recognises this 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.

1.3 The Group is committed to ensuring there is transparency in its business and in its approach to tackling modern slavery throughout its supply chains, consistent with its disclosure obligations under the Modern Slavery Act 2015.  The Company expects the same high standards from all of its suppliers, contractors and other third parties.  As part the Groups contracting processes, it expects that its suppliers will hold their own suppliers to the same standards set out in this policy.

1.4 The board of directors has overall responsibility for ensuring this policy complies with the Groups legal and ethical obligations, and that all those staff and third parties under its control comply with it.

2.0 Who does this policy apply to?

2.1 This policy applies to all persons working for GroupNexus or on its behalf in any capacity, including employees at all levels, directors and front line staff , and third parties including agency workers, customers, suppliers agency workers, volunteers, interns, agents, contractors, external consultants (“third parties”).

3.0 Scope & purpose of policy

3.1 This policy describes how the Group will prevent, detect and report modern slavery in any part of its business or supply chains.

3.2 The Company aims 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. The Group is 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 the business or in any of the Groups supply chains.

Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If any staff member believe they have suffered any such treatment, the individual should inform either their manager or the HR Department immediately.

If the matter is not remedied, an employee should raise it formally in accordance with the local Grievance Procedure, which is published in the company employee handbook.

4.0 Compliance with the policy

4.1 All staff and third parties must comply with this policy and are required to avoid any activity that might lead to, or suggest, a breach of this policy.

4.2 All staff and third parties are required to raise any concerns about any issue or suspicion of modern slavery in any parts of the Groups business or supply chains of any supplier tier at the earliest possible stage.

4.3 If any staff believe or suspect a breach of this policy has occurred or that it may occur, the individual must notify either their line manager or the HR Department and report as a breach of the Group Ethics & Slavery Policy as soon as possible.  If Third parties have any reason to feel a breach has been made they should notify a senior Group manager in the first instance. The strategic lead at executive level that Modern Slavery concerns can be escalated to is the Operations Director.

4.4 If staff or third parties are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of the Groups supply chains constitutes any of the various forms of modern slavery, this should be raised  as set out in paragraph 4.3.

4.5 All managers are responsible for ensuring that this policy and the Groups zero-tolerance approach to modern slavery is communicated to all employees and for ensuring those individuals reporting to them understand and comply with this policy and are given adequate and regular training as applicable on the policy and the issue of modern slavery in supply chains.

4.6 Management have 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.

4.7 All contract managers& Heads of departments who are responsible for procurement of goods and / or services must ensure that this policy and the Groups zero-tolerance approach to modern slavery is communicated to all third parties  during the procurement process and / or at the outset of each business relationship.

4.8 All contract managers & heads of departments are also responsible for ensuring that all relevant  existing third party contracts include obligations to comply with the Modern Slavery Act and new third party contracts contain applicable prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children.

All GroupNexus suppliers must complete a supplier questionnaire relating to quality control (covering Ethical & Slavery Policy commitment) and are assessed as suitable for the approved suppliers on the basis of this questionnaire prior to award of contract. Where the Group feel it is necessary; a representative will/may visit the supplier to ensure that we are completely satisfied with the processes and procedures in place and per the suppliers policy. Those responsible for setting up contracts with suppliers/3rd Party Contractors are to utilise the supplier/sub-contractor questionnaire and forward onto Approved Supplier Register Manager who will be responsible for assessing the suppliers annually for commitment to its policies.

Any supplier or third party contractor who has not completed the questionnaire are to complete Annex A – Template Letter for use with suppliers/sub-Contractors where the contract does not contain a requirement to comply with the Modern Slavery Act 2015.

5.0 Investigations & disciplinary action

5.1The Group line managers are responsible for preparing and carrying out the group induction & refresher training programmes for the employees.  Part of this training will be to cover this policy and how to report breaches.

5.2 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

5.3 The Company may terminate its relationship with other third parties if they breach this policy.

Signed: Ian Langdon

Appointment: Operations Director

Date: 04.01.22 V1.1

Annex A
Template letter for use with suppliers where the contract does not contain a requirement to comply with the Modern Slavery Act 2015.

Dear Supplier

Subject: Modern Slavery Act 2015

You are no doubt aware of the Modern Slavery Act 2015, under which companies who meet the threshold are required to implement and enforce effective systems and controls to ensure modern slavery is not taking place in any of its supply chains.

We have a zero-tolerance approach to modern slavery, which is a crime and a violation of fundamental human rights. We recognise this 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 are committed to acting ethically and with integrity in all our business dealings and relationships with suppliers.

 If you supply goods or services to us, you agree to do so as set out below:

  • in compliance with (and you shall ensure that your sub-contractors comply with) the Modern Slavery Act 2015; and the Robert Half Anti-Slavery Policy (as amended from time to time) available upon request;
  • you also undertake, warrant and represent that you shall implement appropriate due diligence procedures for your own suppliers, sub-contractors and other participants in its supply chains to ensure that there is no slavery or human trafficking in its supply chains; and
  • you agree to notify us and confirm the same promptly in writing immediately upon discovering any breach or potential breach of the Modern Slavery Act or any actual or suspected slavery or human trafficking in your supply chains.

Please confirm your agreement to the above, in addition to any other terms and conditions agreed between the parties, by signing and returning a copy of this letter.

 Yours faithfully

Ian Langdon

Head of Operations

I agree to the above terms relating to the Modern Slavery Act 2015, in the event we supply goods and/or services.

Signature: ………………………………………………   Authorised signatory

Print Name: ……………………………………………   Position: ………………………………………………

Company: ………………………………………………

PCN PAY OR APPEAL