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, all of which involve the deprivation of a person's liberty by another to exploit them for personal or commercial gain.
We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships. We implement and enforce 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 expect the same high standards from all our contractors, suppliers and other business partners, and include specific prohibitions against the use of forced, compulsory or trafficked labour in our contracts.
About this Policy
This policy sets out our responsibilities, and those working for and on our behalf, in observing and upholding our position on modern slavery and human trafficking. It also provides guidance on how to identify and report concerns.
This policy applies to all persons working for us in any capacity, including employees, directors, officers, agency workers, contractors, 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
The CEO has overall responsibility for ensuring compliance. The CFO has day-to-day responsibility for implementation, monitoring, and effectiveness, handling queries, and auditing control systems. Managers must ensure that their teams understand and comply with this policy.
Comments and suggestions are welcomed and should be addressed to the CFO.
Your Responsibilities and Reporting Concerns
Everyone must read, understand and comply with this policy. Preventing, detecting and reporting modern slavery is the responsibility of all who work for or under our control.
If you believe or suspect a breach of this policy has occurred or may occur, notify the CFO or your manager immediately, or report via our Whistleblowing Policy.
We will support anyone raising genuine concerns in good faith. No one will suffer detrimental treatment for reporting suspicions of modern slavery.
Training and Communication
Training on this policy forms part of the induction for those involved in recruitment and supply chain management. Our zero-tolerance approach is communicated to all suppliers and reinforced regularly.
Breaches of this Policy
Employees breaching this policy will face disciplinary action, potentially including dismissal. Our relationships with other organisations breaching this policy may be terminated.
Supply Chains
We rigorously check material supplier chains to minimise risks of slavery and human trafficking. All supplier contracts include anti-slavery clauses applying through all tiers of the supply chain.
Recruitment Practices
Using Agencies
We use only approved, reputable recruitment agencies, conducting background checks, verifying reputations and confirming paperwork and worker eligibility. Approved agents are reviewed at least every 3 years.
General Recruitment
- All staff have written contracts and no recruitment fees are charged to applicants.
- We verify legal working status, and check names and addresses for signs of potential exploitation (e.g. high shared occupancy).
- New recruits receive information about their statutory rights.
- Suspicions of exploitation during recruitment are referred to HR and handled via internal reporting procedures.
Policy Overview
This policy applies to all colleagues, including agency workers and contractors. It provides guidance on Smartology’s Anti-Slavery Policy for management and employees.
Version Control
| Version/Issue No | Type of Change | Date | Description of Change |
|---|---|---|---|
| Issue 1 | Annual review and update | June 2025 | No changes to policy |
When viewed as a printed document, the reader is responsible for confirming that it is the latest version.