Anti-Slavery and Human Trafficking Policy

1. POLICY STATEMENT

1.1 Modern slavery is a crime and a 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 to exploit them for personal or commercial gain.

Samuel Knight International have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in the business or in any part of the supply chains. This will be achieved by ensuring that;

  • All recruitment is carried out in a fair and transparent manner and will comply with relevant legislation and standards.
  • The requirements and expectations made of the supply chain in relation to the act will be clearly communicated and included within contractual terms.
  • Suppliers will be expected to comply with the Immigration, Asylum and Nationality act 2006.
  • The Company will take a partnership approach with regards to working with its suppliers to combat the threat of modern slavery and human trafficking across its sectors and all the industries in which it operates.
  • The Company will train appropriate staff to understand the risks and issues surrounding modern slavery and human trafficking, how to identify it and appropriate measures to prevent it.

1.2 Samuel Knight International are committed to ensuring there is transparency in the business and in their approach to tackling modern slavery throughout their supply chains. Samuel Knight International expect the same high standards from all of their contractors, suppliers and other business partners. As part of the contracting processes, Samuel Knight International include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. Samuel Knight International expect that their suppliers will hold their own suppliers to the same high standards.

1.3 This policy applies to all persons working for Samuel Knight International and/or on their behalf in any capacity including; employees at all levels, contractors, external consultants, third-party representatives and business partners.

2. RESPONSIBILITY FOR THE POLICY

2.1 The CEO has overall responsibility for ensuring this policy complies with Samuel Knight International’s ethical obligations, and that all those under their control comply with it.

2.2. The Operations Director has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

2.3 Managers at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on the issue of modern slavery.

3. COMPLIANCE WITH THE POLICY

3.1 All employees of Samuel Knight International should ensure that they read, understand and comply with this policy.

3.2 The prevention, detection and reporting of modern slavery in any part of the business or supply chains is the responsibility of all those working for Samuel Knight International or under their control. Any activity that might lead to, or suggest, a breach of this policy should be avoided.

3.3 The Operations & Compliance Manager must be told, as soon as possible, if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.

3.4. Concerns about any issue or suspicion of modern slavery in any part of Samuel Knight International’s business or supply chains should be raised with the Operations & Compliance Manager at the earliest possible stage the Operations & Compliance Manager would also encourage the reporting of any concerns or information to be provided to the Modern Slavery Helpline where confidential advice and support is available.

3.5. Breaches or suspicion of breaches of this policy must be notified to a Director or the Operations & Compliance Manager or a report made in accordance with Samuel Knight International’s Whistleblowing Policy as soon as possible.

3.6. Samuel Knight International 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 because 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. Any such treatment will not be tolerated and incidents should be reported to the Operations & Compliance Manager immediately.

4. COMMUNICATION AND AWARENESS OF THIS POLICY

4.1 Training on this policy, and on the risk the business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for
Samuel Knight International.

4.2 Our zero-tolerance approach to modern slavery will be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

5. BREACHES OF THIS POLICY

5.1 Any employee, unless identified as a victim of modern slavery, who breaches this policy will face disciplinary action that may result in dismissal for misconduct or gross misconduct.

5.2 Samuel Knight International will consider terminating our relationship with other individuals and organisations working on our behalf if they breach this policy.

Model Policy No. 35 Version 35/02

Date: March 2019

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