Modern Slavery

Modern slavery is a serious crime involving the exploitation and control of vulnerable people, often for some sort of financial gain or criminal purpose. We have a legal and moral responsibility to ensure that we prevent modern slavery across our global operations and protect vulnerable people from harm. This not only applies to our own employment practices and recruitment policies, but also to those of the suppliers and partners we work with.

• Modern slavery is the world’s fastest growing criminal activity. It is often hidden and difficult to identify.
• Modern slavery involves the exploitation and control of vulnerable people and encompasses human trafficking, forced labour and harmful child labour.
• We have a legal and moral obligation to ensure that we, as well as our suppliers and partners, do not knowingly or unwittingly support or participate in modern slavery.
• Make sure you know how to identify potential cases of modern slavery. Stay alert.
• All breaches of this policy will be treated seriously and may result in criminal and civil prosecution.
• Report any concerns or suspicions you may have using our Speak Up policy.

What do we mean by modern slavery?

There are many types of modern slavery, including:

• human trafficking, which involves transporting people into, out of or within a country for money;
• forced labour (the most common form), where people are made to work against their will. This can be in ‘normal’ jobs as well as in the sex trade or, commonly, domestic
  service. In many cases, their wages are stolen by the person controlling them; and
• harmful child labour (similar to forced labour but relating solely to minors), which affects a child’s education, health or physical, mental, spiritual, moral or social development. In most cases, modern slavery is achieved through the use of force, threats, deception or coercion. Victims may have been abducted or forced to live somewhere against their will.

The Home Office estimates there are up to 13,000 victims and survivors of modern slavery in the UK. 55% of these are female and 35% of all victims are trafficked for sexual exploitation.

Why this matters

Modern slavery is fast becoming the most profitable global criminal activity. It affects people from all backgrounds, ethnic groups, age groups and genders and is often hidden, which is why we all need to be aware of what it means, what to look for and what to do if we suspect it is happening.

To help us guard against unwittingly employing or using the services of somebody who is a victim of modern slavery (and to potentially help them by reporting our concerns), here are some tell-tale signs to look for:

• They appear isolated, with little knowledge of the area. They may also have poor language skills and few personal effects;
• They have no proof of address, or you receive multiple applications from the same address;
• They show signs of distress / trauma, have injuries which may indicate abuse, or look malnourished or exhausted;
• They appear nervous and withdrawn. They don’t talk about their home life or personal circumstances;
• They are regularly picked up and dropped off at work and don’t seem to engage in social activities.

Anti-slavery obligations

All employees, particularly those responsible for recruitment, together with anybody working for us, providing services to us or working on our behalf across our global
operations, must:

• Not use forced or compulsory labour, i.e., any work or service that a worker performs involuntarily or under threat of penalty;
• Comply with the minimum age requirements prescribed by applicable laws;
• Compensate workers with wages and benefits that meet or exceed the legally required minimum for that country;
• Abide by applicable laws concerning the maximum hours of daily labour;
• Take reasonable steps to ensure that any sub-contractors or suppliers from whom they source goods and/or services for ultimate use by us also adhere to these requirements; and
• Bring any actual or potential cases of modern slavery to the attention of our global HR Director immediately for further investigation using our Speak Up (Whistleblowing) procedure.

Audits and non-compliance

Upon request, anybody working for us, providing services to us or working on our behalf must be able to demonstrate compliance with this policy. Collaboration with our partners is the only really effective way to ensure modern slavery is prevented.

We may perform audits at any time. Any company found to have breached this policy or a company that has refused to cooperate with an audit of its employment / recruitment practices may have its supply agreement or other contract with us terminated immediately without compensation. We will also notify the relevant authorities as appropriate.

How to report concerns

If you suspect that somebody has or may be a victim of modern slavery, report your suspicions immediately using our Speak Up policy.

It takes courage to report something that may be a hunch, but we can only investigate and potentially help somebody who may be at risk of modern slavery if we know about it. You don’t need to be 100% sure of your facts so long as you have reasonable grounds for your suspicion.