Our policy
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.
The Company has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business, or in any of our supply chains.
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.
This policy applies to all persons working for us as well as all members and users of any services that we provide.
Responsibility of Employees, Associated Companies and Third Parties
We firmly believe that combating slavery and human trafficking necessitates the active involvement and commitment of all individuals and organisations associated with our business. This includes our employees at all levels, as well as any associated companies and third parties we engage with. We expect everyone within our network to share our dedication to preventing and addressing these heinous crimes. To ensure compliance, we will implement rigorous due diligence procedures to assess the ethical practices of our suppliers, contractors and business partners. We will only engage with those who demonstrate a clear commitment to eradicating slavery and human trafficking from their operations.
Training on Anti-Slavery
We understand the importance of knowledge and awareness in effectively combating slavery and human trafficking. Therefore, we are committed to providing comprehensive training to all our employees. This training will raise awareness about the signs and risks of slavery, enhance their understanding of relevant legislation and regulations and equip them with the necessary skills to identify and report any suspicious activities. By empowering our employees with the knowledge to recognize and respond to potential cases of slavery, we aim to foster a culture of vigilance and accountability within our organisation.
Card Scheme Requirements for Verification and Consent
(a) Verification: In alignment with the requirements set forth by the card schemes, we will implement robust verification processes throughout our supply chain. These processes will include conducting due diligence on suppliers and contractors to ensure they comply with anti-slavery laws and regulations. We will establish clear guidelines for assessing potential risks and implementing appropriate measures to mitigate those risks. Regular audits and monitoring mechanisms will be put in place to evaluate the effectiveness of these verification procedures.
(b) Consent: Respecting the principles of consent is integral to our commitment to combatting slavery. We will ensure that all individuals involved in our operations, including employees and workers, provide their free and informed consent. This will include obtaining consent for employment terms, working conditions, wages and any other relevant aspects. We will maintain transparent and fair communication channels to facilitate ongoing consent and address any concerns or grievances promptly.
Compliance with the Policy
You must ensure that you read, understand and comply with this policy.
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. This issue can be further helped by the vigilant reporting of anything suspicious by our members.
We aim to encourage openness and will support anyone who raises 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 business.
Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.
