Modern Slavery & Human Trafficking Policy

6.3 Modern Slavery & Human Trafficking Policy

6.3.1 Introduction

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. Princebuild 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 committed not only to compliance with the Modern Slavery Act 2015 but to continuous improvement in identifying, preventing and mitigating risks of modern slavery. We will ensure 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 our consultants, suppliers and sub-contractors (together ‘Suppliers’) 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.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, sub-contractors, agency workers, external consultants, volunteers and third-party representatives.

This policy will be reviewed regularly and updated as necessary to reflect changes in legislation, regulatory guidance and best practice.

6.3.2 Responsibility for the Policy

Matthew Pudney, Chief Executive Officer shall be responsible for overseeing and implementing the Policy. Matthew Pudney will also amend as necessary, sign and publish the company’s annual Modern Slavery statement.

The Board of Directors retains overall responsibility for ensuring this policy complies with legal and ethical obligations.

Management at all levels are responsible for ensuring their own personal understanding and implementation of the Policy and also to ensure that those who report to them understand and abide by the Policy. Updates on modern slavery risks, incidents and mitigation actions will be report to the Board.

6.3.3 Employee 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 chain 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.

· You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chain promptly.

· If you believe or suspect that a breach of this policy has occurred or that it may occur, you must notify your manager or follow our procedure in accordance with our Whistleblowing Policy immediately.

· All concerns must be reported promptly to Matthew Pudney, Chief Executive Officer and will be handled in accordance with the Whistleblowing Policy. No employee will suffer detriment for raising concerns and all reports will be treated confidentially where possible.

· If you are unsure whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chain constitutes a breach in legislation then you should raise it with your immediate manager, the Human Resources department or with Mattew Pudney.

· 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 ensure that no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery in whatever form is or may be taking place in any part of our business or in our supply chain. Detrimental treatment includes dismissal, disciplinary action, threats or any other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Human Resources department immediately. If the matter is not remedied to your satisfaction and you are an employee, you should raise it formally in line with our Grievance Policy and Procedure which can be found within the Employee Handbook.

6.3.4 Compliance within the Supply Chain

· We will keep an updated database which includes a supply chain risk assessment that identifies suppliers at high risk or with unclear labour practices on our SharePoint which allows access to all employees. The data base will indicate compliance and non-compliance. Only those in the supply chain who show as compliant will be cleared for use. This will ensure our existing supply chain is compliant with the Modern Slavery Act 2015.

· We will request directly from the supply chain or research all associated website addresses to ensure that their Annual Statement and Policy are in place and that they comply with our own policy as a minimum standard.

· If non-compliance is found, we will contact the supplier concerned and request copies of their Annual Statement and Policy. If these are not presented and accepted within 28 days the relevant supplier will be struck off the recommended list, this will be open to review when an acceptable Policy is presented.

· Matthew Pudney, Chief Executive Officer will conduct an annual audit to ensure that our supply chain policies are in place and are fit for purpose.

6.3.5 Training

Training on this policy, and on the risks 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 is provided as necessary.

Our zero-tolerance approach to 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 on an ongoing basis.

6.3.6 Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which, in some circumstances, could result in dismissal for gross misconduct.

We may terminate our relationship with other suppliers, individuals and organisations working with us or on our behalf if they breach this/their policy.