Modern Day Slavery Policy

Modern Day Slavery Policy

 

About This 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.

Environmental Compliance Limited 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.

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.

This policy applies to all persons working for Environmental Compliance Limited or on our behalf in any
capacity.

This policy does not form part of any employee’s contract of employment and we may amend it at any
time.

 

Compliance With The Policy

 

1. You must ensure that you read, understand and comply with this policy.

2. 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 or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

3. You must notify your line manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.

4. You are encouraged to raise 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.

5. If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your line manager as soon as possible.

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 supply chains constitutes any of the various forms of modern slavery, you must raise it with your line manager as soon as possible.

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 own business or in any of our supply chains.
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 managing director immediately. If the matter is not remedied, and you are an employee, you
should raise it formally using our Grievance Policy.

 

Communication and Awareness of this Policy

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 regular training will be
provided as necessary.

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.

 

Breaches of This Policy

Any employee who breaches this policy will usually 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.