Modern Slavery / Anti-Slavery & Human Trafficking Policy

POLICY NAME Modern Slavery / Anti-Slavery & Human Trafficking Policy
PURPOSE To ensure all employees, suppliers and authorised sub-contractors are aware of the Company’s obligations relating to the Modern Slavery Act 2015 and the measures to be implemented and maintained to ensure legal compliance.
APPLIES TO All employees, suppliers, authorised sub-contractors, casual workers, agency staff, volunteers, interns, agents, sponsors, and any other person associated with the Company or any of its subsidiaries.
DATE IMPLEMENTED April 2023

This policy supersedes the Company’s previous Modern Slavery / Anti-Slavery & Human Trafficking Policy.

1 Introduction

This policy sets out Arctics Ltd (trading as Igloo) hereby referred to as ‘the Company’ obligations relating to the Modern Slavery Act 2015 (“MSA 2015”).

The aim of this policy is to put in place measures that are aimed at ensuring there is no slavery or human trafficking taking place within our businesses and our supply chains.

Given the wide-ranging services offered within the Company, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking. We are absolutely committed to preventing slavery and human trafficking in our corporate activities and our supply chains.

2. Who does this Policy apply to?

The policy applies to all persons working for the Company or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, apprentices, agents, contractors, external consultants, third-party representatives and business partners.

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

3. What is Modern Slavery?

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.

4. What is the Company Stance on Modern Slavery?

The Company has a zero-tolerance approach to modern slavery. 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 MSA 2015.

We expect the same high standards from all 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.

5. Who is covered by this Policy?

This statement covers the activities of the Company in all our business dealings throughout the UK.

6. Who is responsible for ensuring compliance with this Policy?

Ultimate responsibility for adherence to this policy rest solely with the Board of Directors who will ensure this policy complies with our legal and ethical obligations and that all those under their control comply with it.

However, Directors and senior management at all levels within the business will also have responsibility to ensure that this policy is adhered to, ensuring that all those who report to them operate in line with the necessary requirements and are given adequate training on the issue of modern slavery in supply chains.

7. Compliance with this 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.

8. What if I suspect an individual, group or organisation may be in breach of this Policy?

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

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 at the earliest possible stage.

The Company aims 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.

9. What happens if I breach this Policy?

Any employee found to be in breach of this policy may be subject to formal disciplinary action, up to and including summary dismissal for gross misconduct.

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