This policy supports the Company’s commitment to limiting the risk of modern slavery occurring within the FMTS business itself or infiltrating the Company’s supply chains or any other business relationship.
The policy applies to all persons working for or on behalf of the Company in any capacity; this includes employees, directors, officers, agency workers, contractors, consultants or any other third-party representative.
All individuals or businesses that seek a business relationship with the Company should be given notice of and familiarise themselves with this policy and act at all times in a way that is consistent with its values.
This policy will be used to underpin and inform any statement on slavery and human trafficking that the Company is required to provide in order to comply with the transparency in supply chain requirements of Section 54 of the Modern Slavery Act 2015 (referred to as the MSA).
2. What is meant by modern slavery?
Modern slavery can take many forms. The MSA covers four key criminal activities:
• Slavery: where ownership is exercised over an individual
• Servitude: involves the obligation to provide service imposed by coercion
• Forced and compulsory labour: all work or service are not voluntarily performed, and are obtained from an individual under the threat of force or penalty
• Human trafficking: involves arranging or facilitating the travel of one or more individuals with a view to exploiting them
Other forms of modern slavery, which are not specifically referenced in the MSA include, but are not limited to:
Child labour: although not always illegal in the jurisdiction in which it takes places, child labour involves the employment of children that is exploitative, or is likely to be hazardous to, or interfere with, a child’s education, health (including mental health), physical well-being or social development.
All forms of modern slavery have in common the deprivation of a person’s liberty by another in order to exploit them for commercial or personal gain and amount to a violation of an individual’s fundamental human rights.
Tackling modern slavery requires everyone to play a part and remain continuously aware of and vigilant to the risks in all aspect of the Company’s business and business relationships.
3. Enabling our anti-slavery policy in practice
To underpin our policy commitments, we are in the process of implementing the following measures:
• conducting regular risk assessments to determine which aspects and activities of FMTS’ business as well as which of the Company’s supply chains are potentially most susceptible to the risk of modern slavery.
• where appropriate, as informed by the Company’s risk assessment, we will engage directly with suppliers in respect of our anti-slavery policy in order to gain a proper understanding of the measures they have in place to ensure that modern slavery is not occurring within their own businesses. Where appropriate, we will agree what action needs to be taken.
• maintaining clear procedures preventing exploitation and human trafficking, and protecting our workforce and reputation.
• being clear about our recruitment policy.
• making appropriate checks on all employees, recruitment agencies, suppliers, etc. to ensure we know who is working for us.
• seeking to raise awareness so that our colleagues know what we are doing to promote welfare.
4. Responsibility for this policy
The Board has overall responsibility for this policy in order to ensure that the Company complies with its legal and ethical obligations.
The HR department will have primary day-to-day responsibility for the implementation of this policy, monitoring its use and ensuring that the appropriate processes and control systems are in place, amended as appropriate, to ensure it can operate effectively.
All senior managers are responsible for ensuring that those reporting directly to them comply with the provisions of this policy in the day-to-day performance of their roles.
• listen and be approachable to colleagues
• respond appropriately if they are told something that might indicate a colleague or any other person is in an exploitative situation
• remain alert to indicators of slavery (see Identifying slavery)
• raise the awareness of our colleagues, by discussing issues and providing training, so that everyone can spot the signs of trafficking and exploitation and know what to do
• use their experience and professional judgment to gauge situations
We all have responsibilities under this policy. Whatever your role or level of seniority, you must keep your eyes and ears open—if you suspect someone (a colleague or someone in our supply chain) is being controlled or forced by someone else to work or provide services, follow our reporting procedure; follow our reporting procedure if a colleague tells you something you think might indicate they are or someone else is being exploited or ill-treated and tell the Company if you think there is more we can do to prevent people from being exploited.
5. Communication and employee awareness training
Senior managers will ensure that all relevant staff receive adequate training in this policy and any supporting processes applicable to their role. Such training will form part of the Company’s induction process.
Relevant staff will receive refresher training on the broader issues of modern slavery so as to assist them in appreciating the extent of the problem of modern slavery and to identify individuals/areas of the business that may be at risk from such activities and practices.
6. Breaches of this policy
Any breaches of this policy will be taken seriously and dealt with on a case-by-case basis.
Any breach of this policy by an employee of the Company may lead to disciplinary action being taken in accordance with the Company’s disciplinary procedure.
Serious breaches may be regarded as gross misconduct and may lead to immediate dismissal.
Everybody to whom this policy applies will be expected to co-operate to the fullest extent possible in any investigation into suspected breaches of this policy or any related processes or procedures.
If any part of this policy is unclear, clarification should be sought from the HR manager.
7. Status of this policy
This Anti-slavery policy will be reviewed by the Company’s Board on a regular basis.
This policy does not give contractual rights to the Company employees, suppliers or customers and the Company reserves the right to alter any of its terms at any time. The latest version of this policy will be available on the Company’s website.