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Modern Slavery Act

1. Aim / Purpose

The aim of this policy is to combat slavery and to implement the Modern Slavery Act 2015.

 

2. Scope

This policy applies to all persons working for GRENKELEASING Ltd. 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 entities with whom we carry out business.

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

 

3. Policy statement

1.1 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 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.

1.2 Whilst given the nature of our business modern slavery considerations are less likely to arise in our own business than that of other industries, we are committed 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 entities with whom we carry out business, and as part of our contracting processes, we include specific prohibitions in our documents against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect and require in our documentation that our suppliers will hold their own suppliers to the same high standards. 

 

2. Compliance with the policy

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

2.2 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.

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

2.4 If you believe or suspect a breach of this policy has occurred (or that it may occur), you must notify your manager as soon as possible. You should note that where appropriate, and with the welfare and safety of local workers as a priority, we may give support and guidance to our suppliers to help them address coercive or exploitative work practices in their own business and supply chains.

2.5 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, please raise it with your manager.

2.6 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.

 

3. Communication and awareness of this policy

3.1 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.

3.2 Our commitment to addressing the issue of modern slavery in our 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 thereafter.

 

4. Breaches of this policy

4.1 Please be aware that any employee who breaches this policy will 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.