1. 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 have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain. The company has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its own business or in any part of its supply chain.
The company is also committed to ensuring there is transparency in its own business and in its approach to tackling modern slavery throughout its supply chains, consistent with disclosure obligations under the Modern Slavery Act 2015. The company expects the same high standards from each of its contractors, suppliers and other business partners.
Reference in this policy to “the company” means Adefey Group LTD / Brighter Tomorrow LTD and any subsidiary and holding company or group company of them, collectively referred to in this policy as “the company.”
2. About This Policy
This policy applies to all persons working for the company or on its behalf in any capacity, including employees at all levels, directors, officers, interns, agents, contractors, external consultants, third-party representatives, and business partners.
This policy does not form part of any employee’s contract of employment. We reserve the right to amend or remove this policy.
3. Responsibility for the Policy
The board of directors of each of the company business has overall responsibility for ensuring this policy complies with legal and ethical obligations, and that all those under its control comply with it.
Michael Koublanou, Operations Manager (CQC Registered) is the MSA officer and has primary and day-to-day responsibility for implementing this policy and monitoring its use and effectiveness.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy.
4. Compliance with the Policy
The prevention, detection and reporting of modern slavery in any part of the business or supply chain is the responsibility of all those working for the company under its control.
All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
Employees must notify their line manager or the nominated MSA Officer as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future.
Employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of the business or supply chain of any supplier at the earliest possible stage.
If an employee believes or suspects that a breach of this policy has occurred (ref HR36, Appendix 01 – Indicators of Modern Slavery) or that it may occur a report must be made to the appropriate line manager or report must be made as soon as possible in accordance with the HR35. Whistleblowing Policy. We will take seriously all reports received raising concerns regarding modern slavery within our business and its supply chain, and we will investigate each one.
If an employee is unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any of the company’s supply chain constitutes any of the various forms of modern slavery, it must be raised with the appropriate line manager or the nominated MSA Officer.
The company aims 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.
The company is 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 the 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 any member of staff believes that they have suffered any such treatment, they should inform the nominated MSA Officer immediately. If the matter is not remedied, and the member of staff should raise it formally using our HR13. Grievance Procedure.
5. Communication and Awareness of this Policy
Appropriate training on this policy, and on the risk that the company business faces from modern slavery in its supply chains will be provided as necessary to targeted staff.
A zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of any business relationship with them and reinforced as appropriate thereafter.
The company will provide a Modern Slavery Suppliers Questionnaire (HR36, Appendix 03) to all suppliers to complete in relation to Modern Slavery and return to the company.
6. Breaches of this Policy
Any employee who breaches this policy may face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
The company may terminate its relationship with other individuals and organisations working on its behalf if they breach this policy.
Appendices
HR36, Appendix 01 – Indicators of Modern Slavery
HR36, Appendix 02 – Modern Slavery Suppliers Questionnaire
