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 in order to exploit them for
personal or commercial gain.
Project X Office has 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.
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, in the coming year we will 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.
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, seconded workers, volunteers, interns, agents, 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
for the policy
Project X Office has overall responsibility for ensuring this
policy complies with our legal and ethical obligations, and that all those
under our control comply with it.
Project X Office 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.
Management 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 it and the issue of modern slavery in supply
chains.
You are invited to comment on this policy and suggest ways
in which it might be improved. Comments, suggestions and queries are encouraged
and should be addressed to the Managing Director.
Compliance
with the policy
You must ensure that you read, understand and comply with
this policy.
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. You must notify your
line manager OR a 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
line manager or company Director OR report it in accordance with our
Whistleblowing Policy as soon as possible.
You should note that where appropriate, and with the welfare
and safety of local workers as a priority, we will give support and guidance to
our suppliers to help them address coercive, abusive and exploitative work
practices in their own business and supply chains.
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 line manager or 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 line manager immediately. If the matter is not remedied,
and you are an employee, you should raise it formally using our Grievance
Procedure, which can be found in the current employee handbook.
Communication
& awareness of this policy
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, and updates will be provided using
established methods of communication between the business and you. Our
zero-tolerance approach to modern slavery must be communicated to all
suppliers, contractors and business partners at the outset of our business
relationship with them and reinforced as appropriate thereafter.
Breaches
of this policy
Any employee who breaches this policy will face disciplinary
action, which could result in dismissal for misconduct or gross misconduct. We
may terminate our relationship with other individuals and organisations working
on our behalf if they breach this policy.
Printed and Signed Off By: J. ORFORD (Director) 2021