Modern Slavery Statement

We are committed to ensuring that slavery and human trafficking are not taking place in our organisation or any of our supply chains. We have a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships.

Introduction and commitment

Although we have only recently set up (March 2021) and we are a small organisation, to help us identify and mitigate risks of slavery and human trafficking, we have the following protections in place.

  1. We are committed to ensuring there is openness in our own business operations and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.
  1. As part of our due diligence in selecting contractors, suppliers and other business partners, we look for upholding the same high standards consistently.
  1. 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, 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.

Responsibility for the policy

The Company has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The company directors 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 control systems and procedures to ensure they are effective in countering modern slavery.

The company directors as well as management at all levels of organisations in our supply chain 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.

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 Martin Wills c/o MWA Accounting, 1b Blackfriars House, Parsonage, Manchester M3 2JA  

Compliance with the policy 

The company directors will aim to ensure:

  • In addition to due diligence in the selection of contractors, suppliers and other business partners, we will also review these business relationships on a yearly basis.
  • All persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners must read, understand and comply with this policy.
  • All persons working for us or on our behalf in any capacity are empowered to take responsibility for:
    • the prevention, detection and reporting of modern slavery in any part of our business or supply chains,
    • raising 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.
    • notifying Martin Wills or Katalin Marton (company directors) as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy.

Communication & awareness of this policy

We will publish this policy on our website.

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 updates will be provided using established methods of communication.

Our zero-tolerance approach to modern slavery must be communicated to suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Breaches of this policy 

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

 

This statement was approved by the company directors:

Martin Wills

Katalin Marton

 

August 2021