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 commit to ethical actions and maintaining integrity in all our business dealings. We will enforce systems to ensure modern slavery does not occur in our business or supply chains.
We commit to transparency in our business. We will also be open about our efforts to combat modern slavery in our supply chains. This is in line with the Modern Slavery Act 2015.
We expect the same high standards from all contractors, suppliers, and partners. In our contracts, we will include specific bans on using forced, compulsory, or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect our suppliers to hold their own suppliers to the same high standards.
This policy applies to all persons working for us or on our behalf in any capacity. This includes employees at all levels, and directors and officers. It also includes agency workers, seconded workers, volunteers, 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.
The Company must ensure this policy meets our legal and ethical duties. It must also ensure that everyone under our control complies with it.
The Company is mainly responsible for this policy. It must implement it, monitor its use and effectiveness, answer queries, and audit internal controls to counter modern slavery.
All levels of management are responsible for this policy. They must ensure their reports understand and follow it. They must also provide regular, adequate training on it and modern slavery in supply chains.
We invite you to comment on this policy and suggest ways to improve it. Please send comments, suggestions, and queries to the Managing Director.
You must ensure that you read, understand and comply with this policy.
Everyone working for us or under our control must prevent, detect, and report modern slavery in our business and supply chains. You are required to avoid any activity that might lead to, or suggest, a breach of this policy. Notify your line manager or a Director as soon as possible if you believe or suspect a conflict with this policy may have occurred or may occur.
You should raise concerns about modern slavery in our business or any supplier tier at the earliest opportunity. If you believe or suspect a breach of this policy, you must notify your line manager or company Director.
We will, where appropriate, support our suppliers. Our priority is the welfare and safety of local workers. We will help suppliers end abusive and exploitative work practices in their businesses and supply chains.
If unsure about modern slavery in our supply chains, raise it with your line manager or a company Director.
We aim to encourage openness. We will support anyone who, in good faith, raises concerns under this policy, even if they are mistaken. We are committed to ensuring that no one harms others for, in good faith, reporting their suspicion of modern slavery in our business or supply chains.
Detrimental treatment includes dismissal, discipline, threats, or other bad treatment due to raising a concern.
If you think you have suffered such treatment, inform your line manager immediately. If the issue is not fixed and you are an employee, please raise it using the Grievance Procedure in the employee handbook.
All staff must do an induction. It includes training on this policy and on modern slavery risks in our supply chains. We will provide updates using our established communication methods. We must tell all suppliers, contractors, and partners, at the start of our relationship, our zero-tolerance to modern slavery. We should reinforce it as needed thereafter.
Any employee who breaches this policy will face disciplinary action. This could lead to dismissal for misconduct or gross misconduct. We may end our relationship with those working for us if they breach this policy.
Approved by…
Julyan Mills
Managing Director
Cape Creative & Digital Ltd
1st November 2024