Modern Slavery and Human Trafficking Policy

Policy statement

Modern slavery is a term used to encompass slavery, forced and compulsory labour and human trafficking of children and adults, and any activity that leads to the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. It is a crime and a violation of fundamental human rights.

We have 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 organisation or in any of our supply chains.

We are committed to ensuring there is transparency in our organisation 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. 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. We expect that our suppliers will hold their own suppliers to the same high standards.

Mitigating risk

We require our principal suppliers to confirm that they comply with the requirements of the Modern Slavery Act 2015.

We limit the geographical scope of our operations to ensure optimum supervision of the use of our properties.

Where possible we build long standing relationships with local suppliers and make clear our expectations of business behaviour.

Our supply chain is principally UK based. With international supply chains, our point of contact is with a UK company or branch and we require these entities to have suitable anti-slavery and human trafficking policies and processes. We expect each entity in the supply chain to, at least, adopt ‘one-up’ due diligence on the next link in the chain. It is not practical for us (and every other participant in the chain) to have a direct relationship with all links in the supply chain, ultimately to the primary source of production.

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff and all Directors are kept fully briefed.

Scope of the document

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 business partners.

Roles and responsibilities

The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

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

Colleagues must ensure that they 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. Colleagues are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Colleagues must notify management or email either whistleblowing@hanover.org.uk or whistleblowing@anchor.org.uk as soon as possible if they believe or suspect that a breach of this policy has occurred, or may occur in the future. They 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 there is uncertainty 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, this should also be raised with management or through whistleblowing@hanover.org.uk or whistleblowing@anchor.org.uk.

We 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 in 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 colleagues believe that they have suffered any such treatment, they should inform a manager immediately.

Equality and diversity

We are committed to respecting diversity in all aspects of our work and meeting our obligations under the Equality Act. In line with this, we welcome feedback on any aspect of this policy where there is a question over its adherence to the above legislation.

Data Protection

We are committed to applying this policy in line with the General Data Protection Regulations as set out in our Data Protection Policy.

Recording and monitoring

Reports of actual and potential breaches are reported to the Board. Efficacy of controls is reviewed as part of the Internal and External Audit process.

Commitment and review

The Board looks to the support and professionalism of staff at all levels in making this policy truly effective. This policy statement, along with other related supporting policies and procedures in use, will be regularly reviewed and revised as and when necessary.

Approved by the Anchor Hanover Shadow Board on the 11 September 2018.

Regulatory and legal references

Modern Slavery Act 2015.