Anti-Slavery Policy

Policy Statement

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 zero­tolerance 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 which seek 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, service partners and all other business partners and, as part of our contracting processes, we include specific prohibitions in commercial contracts 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 service partners 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, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and all business partners.

Responsibility for the Policy

Our Board of Directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

Our Company Secretary, Kate Phillips, has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing any internal control systems and procedures to ensure they are effective in countering modern slavery.

Staff at all levels are responsible for ensuring those reporting to them understand and comply with this policy.

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

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 our Company Secretary, Kate Phillips immediately.

Communication and Awareness of this Policy

Our zero-tolerance approach to modern slavery in our business and supply chains is communicated to all service partners, suppliers, contractors, consultants and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Breaches of this Policy

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

If you have any issues, concerns or complaints, please contact us by email hello@ashdownphillips.com.