1. Policy Statement
1.1 Modern slavery is a crime and a gross 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. Clipper 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 own business or in any of our supply chains.
1.2 We are also committed to ensuring there is transparency in our own business 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, 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.
1.3 This policy applies to all persons working for us or on our behalf in any capacity, including colleagues at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
1.4 This policy does not form part of any colleague’s contract of employment and we may amend it at any time.
2. Responsibility for the Policy
2.1 At parent Company level 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.
2.2 The management of the policy is delegated to the operating Company Boards for UK Logistics, Service Care and Northern Commercials.
2.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate training and awareness.
2.4 Colleagues at all levels are responsible for reporting any incidents they know or reasonably believe may breach this policy.
3. Compliance with the Policy
3.1 The HR Director is nominated as the Company Compliance Manager.
3.2 You must ensure that you read, understand and comply with this policy.
3.3 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.
3.4 You must notify your manager or the compliance manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
3.5 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.
3.6 If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or the Compliance Manager or report it in accordance with our Whistleblowing Policy as soon as possible.
3.7 As defined earlier modern slavery takes many forms, all of which are sensitive and some, such as trafficking, could be dangerous. You are not therefore expected to confront issues directly. Once reported to the Company, based on the circumstances, a decision will be taken as to whether to inform the police or other such relevant authorities.
3.8 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 Compliance Manager.
3.9 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 the compliance manager immediately. If the matter is not remedied, and you are a colleague, you should raise it formally using our Grievance Procedure, which can be found in the company handbook and in your contract of employment.
4. Communication and Awareness of this Policy
4.1 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.
4.2 Communication thereafter will be via notice boards, ‘flyers’ and other means as deemed appropriate.
4.3 Our zero-tolerance approach to modern slavery is articulated in a statement which is accessible from the Clipper Logistics plc web site.
4.4 Our zero-tolerance approach to modern slavery must also be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter. See letters in appendices 1 & 2.
5. Breaches of this Policy
5.1 Any colleague who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
5.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.