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 have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealing and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our group.
1.2	We are also committed to ensuring there is transparency in our own businesses in our approach to tackling modern slavery throughout, 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.
1.3	This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, agency workers, contractors, external consultants and third-party representatives and business partners.
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 compliance manager 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.
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 compliance manager.
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 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 your manager or the compliance officer 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 of any supplier tier at the earliest possible stage.
3.5	If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your manager or report it to the compliance officer at the earliest possible opportunity.
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 suppliers constitutes any of the various forms of modern slavery, raise it with your manager or the compliance officer.
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 group. 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 compliance officer immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the business Grievance Procedure.
4.1	Training on this policy, and on the risk our business faces from modern slavery, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
4.2	Our zero-tolerance approach to modern slavery 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.