Anti-Slavery Policy
This is the anti-slavery policy of Michael Wenman Ltd and its group companies (“us”, “we”, “our”).
The purpose of this policy is to:
(a) set out our responsibilities, and of those working for and on our behalf, in observing
and upholding our position on modern slavery and human trafficking; and
(b) provide information to those working for and on our behalf on how to identify and
report concerns regarding modern slavery and human trafficking.
- 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 are committed to acting ethically and with integrity in our
business dealings and relationships and are committed to preventing modern slavery in our
own business and to helping prevent modern slavery in 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. Under the Modern Slavery Act 2015, we are legally
required to disclose the steps we take to tackle modern slavery. We expect the same high
standards from all of our employees and suppliers.
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, suppliers, seconded workers,
volunteers, and interns.
1.4 This policy does not form part of any our employee’s contract of employment and we may
amend it at any time.
- RESPONSIBILITY FOR THIS 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 Legal and People departments have primary and day-to-day responsibility for
implementing this policy, monitoring its use and effectiveness, dealing with any queries about
it, and auditing internal procedures.
2.3 Management at all levels are responsible for ensuring those reporting to them understand and
comply with this policy. Guidance on the policy can be obtained from the Legal and People
teams.
- COMPLIANCE WITH THIS POLICY
3.1 The prevention, detection and reporting of modern slavery in any part of our business or supply
chains are 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.
3.2 You must notify your manager (or your main point of contact at Michael Wenman, if you are a supplier) as soon as possible if you believe or suspect that a breach of this policy has occurred, or may occur in the future.
3.3 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any
parts of our business or supply chains or any supplier tier at the earliest possible stage.
3.4 If you believe or suspect a breach of this policy has occurred or that it may occur you must
notify your manager (or your main point of contact at Michael Wenman, if you are a supplier) as soon as
possible.
3.5 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 chain constitute any of the various forms
of modern slavery, you should raise it with your manager (or your main point of contact at
Michael Wenman, if you are a supplier).
3.6 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 by Michael Wenman 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 the Chief People
Officer immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our grievance procedure.
- 4. COMMUNICATION AND AWARENESS OF THIS POLICY
4.1 Guidance on this policy forms part of the induction process for all individuals who work for us
and will be provided otherwise as necessary.
4.2 We provide annual training on identifying and preventing modern slavery in our business and
supply chain. Participation is mandatory.
4.3 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 on an ongoing basis. This is done in
particular by following our supplier due diligence process.
- 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.
5.2 We may terminate our relationship with other individuals and organisations w