Irwin M&E

Modern Slavery Policy

Policy Statement

 

Modern Slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour, and human trafficking, all of which involve the deprivation of a person’s liberty for personal or commercial gain.

  • We have a zero-tolerance approach to modern slavery. 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 business or supply chains.
  • We are committed to transparency in our business and in our approach to tackling modern slavery, in line with our obligations under the Modern Slavery Act 2015. We expect the same high standards from all contractors, suppliers and business partners. As part of our contracting processes, we prohibit the use of forced, compulsory or trafficked labour, or any form of slavery or servitude, whether involving adults or children.

This policy applies to all persons working for or on behalf of the Company in any capacity.

 

Responsibility for the policy

 

  • The Board of Directors has overall responsibility for ensuring compliance with legal and ethical obligations.
  • The HR Department is responsible for implementation, monitoring effectiveness, and auditing.
  • Management at all levels are responsible for ensuring compliance within their teams.
  • Employees are encouraged to provide feedback on this policy.

 

Compliance with the policy

 

  • You must read, understand and comply with this policy.
  • The prevention, detection and reporting of modern slavery is the responsibility of all employees.
  • You must avoid any activity that may lead to, or suggest, a breach of this policy.
  • You must report concerns or suspected breaches to the HR Department as soon as possible.
  • Where appropriate, the Company will support suppliers in addressing exploitative practices.
  • If unsure whether a situation constitutes modern slavery, raise it with your line manager/HR.
  • The Company will support anyone raising concerns in good faith and will ensure no one suffers detrimental treatment as a result of reporting.

 

Communication and awareness of this policy

 

  • Training on this policy forms part of induction and ongoing learning.
  • Our zero-tolerance approach will be communicated to all suppliers and partners.

 

Breaches of this policy

 

  • Any breach may result in disciplinary action, up to and including dismissal.
  • The Company may terminate relationships with third parties who breach this policy.

 

Monitoring and review

 

The Company will review this policy annually after implementation and update as required.

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