Anti-Slavery and Human Trafficking Policy


Purpose

 

Modern slavery is a criminal offence under the Modern Slavery Act 2015 and is a violation of human rights. It can occur in various forms, such as slavery, servitude, forced or 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.

This sets out the policy of Refractis Limited (“Refractis”) with the aim of the prevention of opportunities for modern slavery to occur within its business or supply chain.


Policy

 

Refractis has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in our business dealings and relationships and to ensuring that modern slavery is not taking place anywhere within our own business or those of our suppliers.

We expect the same high standards from our contractors, suppliers and other business partners.

The detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control.

Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Employees most promptly notify a Refractis Managing Director if they believe or suspect that a violation or conflict with this policy has occurred or may occur in the future.

We aim to encourage openness and transparency and will support anyone who raises genuine concerns in good faith under this policy, even if it turns out to be mistaken.


Responsibilities

 

The Refractis Board has overall responsibility for ensuring this policy and its implementation comply with our legal and ethical obligations.

Managing Directors are responsible for ensuring that:

  • All employees understand and comply with this policy; and

  • Any contractors and suppliers engaged by Refractis understand our zero-tolerance approach to modern slavery and have their own appropriate anti-slavery policies in place.


Enforcement

 

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.


Definitions

 

“Modern slavery” is defined as the recruitment, movement, harbouring or receiving of children, women or men through the use of force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation. It includes holding a person in a position of slavery, servitude forced or compulsory labour, or facilitating their travel with the intention of exploiting them soon after.


Policy review period

 

Following its initial adoption, this Anti-Slavery and Human Trafficking Policy will be reviewed by a Refractis Managing Director on an annual basis and may be amended from time to time.