Anti Slavery and Human Trafficking Policy
Anti Slavery and Human Trafficking Policy
Anti Slavery and Human Trafficking Policy
Anti-Slavery and
Human Trafficking
Policy
July 2018
This policy sets out our expectations and commitments in accordance with
the Modern Slavery Act 2015.
We have zero tolerance for slavery and human trafficking in any part of our
business, including our supply chains. We have a number of policies in place
to ensure all our employees have the right to work and are paid fairly, that we
act with integrity and ethically, and that we have effective measures in place
to ensure slavery is not present anywhere in our business or supply chain.
This includes our Equal Opportunities policy, which encompasses
recruitment, promotion, training, performance management and reward. Our
principles of fair treatment and respect are also applied to our relationships
with customers, suppliers, contractors, shareholders and other stakeholders.
1. Policy statement
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.
1.4 This policy does not form part of any employee's contract of employment and
we may amend it at any time.
2.1 The Board 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 Group HR Director 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 the Group HR Director.
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 Group HR Director 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.
3.6 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
the Group HR Director.
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 the Group HR Director immediately. If the matter is not
remedied, and you are an employee, you should raise it formally using our
Grievance Procedure, which can be found in the Employee Handbook on the
GlobalData intranet.
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 commitment to addressing the issue of 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.
5.1 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
working on our behalf if they breach this policy.