Anti Slavery & Human Trafficking Policy

Modern Slavery Policy

Purpose

The purpose of this policy is to provide guidelines consistent with the Modern Slavery Act 2015, for dealing with the threat of violation of human rights through modern slavery and trafficking within our business or supply chains.

Scope

This procedure applies to all Ecology Co-op employees, contractors, consultants, and temporary staff. It is to be invoked whenever there is an event which compromises the human rights our employees or supply chain staff, in contravention of the Modern Slavery Act 2015.

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, 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.

Responsibility

The responsibility for this procedure lies with the Managing Director, its day-to-day implementation is the responsibility of the Operations Manager / Management Team.

Modern slavery is a crime and a violation of fundamental human rights and we all have responsibility to report it in all its 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.

The Ecology Co-op has a zero-tolerance approach to modern slavery and trafficking, and we are committed to acting ethically and with integrity in all our business dealings and relationships. 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 expect the same zero tolerance approach all of 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.

Procedure

Identification: Any such incident should be immediately reported to the Operations Manager, who will issue an Incident Report Form (Ref: [1]) and log the incident on the Incident Report Log.

Reporting: Any violation of human rights through modern slavery and trafficking within our business or supply chains should be immediately reported to the Operations Manager and Managing Director, who will ensure the incident is raised as an NCR as per the file path above but in addition reported to the proper authorities as required under the obligations of the legislation.

Response: The response, escalation and reporting of the incident will be discussed and determined by the Operations Manager / Management Team and the relevant authorities.

You must notify your manager or Company Director 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 tier at the earliest possible stage.If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your manager or report it to the Company Director as soon as possible.

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, raise it with your manager or the Company Director.

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.

If you believe that you have suffered any such treatment, you should inform your compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally through your line manager.

Post incident review

Preventive actions will be agreed and documented as part of the non-conformity process, the incident shall cross reference the NCR report. All NCRs will be held open until all actions complete, then signed off by the Operations Manager.