Modern Day Slavery & Trafficking Act 2015
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.
Soper of Lincoln Ltd 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 dealing with our responsibility to eradicate modern slavery throughout our supply chains.
We expect the same high standards from all of our contractors, suppliers and other business partners and will abide by our responsibility to ensure that those we deal with exercise 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 Soper of Lincoln Ltd or on our behalf in any capacity, including employees at all levels, directors, contractors, suppliers, external consultants, third-party representatives and business partners.
Responsibility for the Policy
- The Managing Director has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
- The Managing Director 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.
- 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 in supply chains.
Compliance with the Policy
- All employees must read, understand and comply with this policy.
- The prevention, detection and reporting of modern slavery in any part of the business or supply chains is the responsibility of all those working for Soper of Lincoln or under its control. Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
- Employees must notify the Managing Director if they believe or suspect that a conflict with this policy has occurred, or may occur in the future.
- Employees 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.
- If a breach of this policy has occurred, Management must be notified and reported in accordance with the Whistleblowing Policy as soon as possible.
- If anyone is 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, it must be raised with Senior Management.
- Soper of Lincoln 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. 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.
We have endeavoured to put safeguards in place to ensure, so far as is reasonably practicable, that the working practices of those employed directly by us and those with whom we have a direct contractual arrangement with, also have a similar zero tolerance to Modern Slavery.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
In the next 12 months we will continue to evolve and strengthen our approach to managing the risk of Modern Slavery within our business and ensure our strategy is responsive to changing risks.
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes Soper of Lincoln’s Modern Slavery statement for the financial year ending 31 December 2018.
1 March 2019