Anti-Slavery & Human Trafficking Policy

Last updated: July 2024 | Issued by: Ross Buck | Version: 1.3 July 2024

POLICY STATEMENT

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 (“modern slavery”), all of which include the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Anglian has a zero-tolerance approach to modern slavery within its business and supply chain and is committed to ensuring that all its business operations are free from involvement with slavery or human trafficking. This policy applies to all employees of Anglian including third parties such as workers, contractors, external consultants, agencies, customers, clients, and suppliers.

Anglian complies with the Modern Slavery Act 2015 and is committed to;

• ensuring that slavery and human trafficking is considered and addressed in our approach to corporate social responsibility;

• acting ethically and with integrity in all our business dealings and relationships;

• ensuring that any concerns about slavery or human trafficking can be raised through our whistleblowing procedure;

• identifying and addressing any areas of high risk in our supply chain;

• carrying out regular audits to ensure that all our employee’s details are monitored for patterns relating to slavery or human trafficking (same bank account details, addresses, etc) and employees are paid at least the National Minimum Wage and have the documentation to support the right to work in the UK;

• ensuring that all commercial agreements include an obligation on our suppliers to operate in accordance with the Modern Slavery Act 2015, and to ensure that any of their suppliers and sub-contractors also operate in accordance with the Act;

• providing training for all employees who are involved in the supply chain on issues relating to slavery and human trafficking.

IDENTIFICATION

Modern slavery may be found in:

• our business, for example, our workforce;
• our supply chains;
• outsourced activities, particularly to jurisdictions that may not have adequate modern slavery safeguards.
• Anglian expects the same high standards from our suppliers, clients, and customers. As part of the contracting process, we include specific prohibitions against modern slavery and human trafficking.

RESPONSIBITY & REPORTING

The management board of Anglian (these persons are the Directors and the HR Manager) are named persons responsible for ensuring this policy is complied with and meets legal obligations under the Modern Slavery Act 2015.

All employees and third parties who work with Anglian must comply with this policy at all times.

Employees and third parties are encouraged to report as soon as possible if they have any suspicion or concerns regarding modern slavery or human trafficking to the HR department of Anglian. You must follow the reporting requirements under the whistleblowing procedure outlined in the whistleblowing and protected disclosure policy. Further information is available from the HR department.

BREACHES OF THIS POLICY

Any employee who breaches this policy may face disciplinary action, under our disciplinary procedure, which could result in summary dismissal. Anglian may also terminate its relationship with a supplier, client, or customer if it is in breach of this policy. Alternatively, the relevant management of Anglian may elect to work with the third party to resolve such issues.

REVIEW

Anglian reserves the right to make amendments to this policy at any time without notice and it may be subject to review, amendment, or withdrawal. Anglian will notify you of any changes in response to exceptional circumstances, organisational changes, or relevant changes in legislation or guidance as appropriate. This policy will be reviewed annually. The HR department is responsible for reviewing this policy as necessary to ensure that it meets legal requirements and reflects best practice.