All employees of the Anglian Group, together with any individual or organisation that works for or with the Company.
This Policy should be read in conjunction with our Modern Slavery Act Transparency Statement. Modern slavery encompasses slavery, servitude, human trafficking and forced labour and is a crime resulting in an abhorrent abuse of human rights.
Anglian has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place in any of our supply chains or any part of our business. We expect that our suppliers and sub-contractors will hold themselves and their own suppliers and sub-contractors to the same high standards.
We recognise that a focus on tackling modern slavery not only protects vulnerable workers and helps prevent and remedy human rights violations, it can also bring a number of business benefits including, enhancing the company’s reputation and brand, growing the Company’s customer base as more consumers seek out businesses with higher ethical standards, greater staff retention and loyalty based on values and respect and developing more responsive, stable and innovative supply chains.
Everyone who works for the Company has a responsibility to prevent and identify modern slavery in any part of our business or supply chains and must avoid any activity that is contrary to this Policy. We expect those who work for and with the Company to come forward promptly and voice their concerns should they have reason to suspect actual or potential issues with modern slavery in any of our supply chains or any part of our business.
The aims of this policy are to:
Slavery is the condition in which a person is owned as property by another who has absolute power over that person. Since legal ‘ownership’ of a person is not possible, the key element of slavery is the behaviour on the part of the offender as if he/she did own the person, which deprives the victim of their freedom.
Servitude is the obligation to provide services that is imposed by the use of coercion and includes the obligation for a person to live on another person’s property and the impossibility of changing his or her condition.
Forced or compulsory labour involves coercion, either through the direct threat of violence or more subtle forms of compulsion. The key elements are that work or service is exacted from any person under the menace of any penalty and for which the person has not offered him/her self voluntarily.
An offence of Human Trafficking is committed where a person arranges or facilitates the travel of another person with a view to that person being exploited. The offence can be committed even where the victim consents to the travel. This reflects the fact that a victim may be deceived by the promise of a better life or job or may be a child who is influenced to travel by an adult. The exploitation of the potential victim does not need to have taken place for the offence to be committed.
The Board of Directors has ultimate responsibility for the Policy and will:
Directors, Managers and Supervisors will:
The Procurement Department will:
All Employees will:
Others – All other persons will be:
Our current Modern Slavery Transparency statement sets out the steps undertaken and planned during the financial year to ensure that modern slavery or human trafficking is not taking place in any of our supply chains and in any part of our own business.
This statement is published on our external Company website.
An individual raising a concern regarding an actual or potential issue with modern slavery should do so using the procedure set out in the Company’s Whistleblowing Policy (link).
Concerns will be taken seriously, investigated as appropriate and the confidentiality of individuals who raise concerns will be respected.
If the concern relates to the actions of a third party, such as a supplier or sub-contractor, the law allows an individual to raise the concern with that third party where they reasonably believe it relates mainly to their actions or is something that is legally their responsibility. However, we encourage individuals to report such concerns internally first.
Further information and guidance is available from the Whistleblowing Policy or the Company’s Whistleblowing Officer whose contact details are at the end of this Policy.
If an individual is uncertain whether a suspected actual or potential issue constitutes modern slavery they should seek guidance from their manager or the Whistleblowing Officer.
The Modern Slavery Helpline is also able to provide information and guidance to anyone who thinks they may have come across an instance of modern slavery. Their contact details are at the end of this Policy.
The Company will protect and support individuals who raise genuine concerns under the Whistleblowing Policy, even if they turn out to be mistaken. The Company guarantees that individuals will not suffer detrimental treatment from the Company as a result of raising a concern under the Whistleblowing Policy. The Company will also protect individuals from any detriment caused by or on behalf of aggrieved employees or other individuals.
Further information regarding the protection and support for individuals who raise a concern is available from the Whistleblowing Policy.
Any individual who believes that they have suffered any detriment by reason of raising a concern regarding an issue with modern slavery should inform the Whistleblowing Officer immediately.
This Policy does not form part of any employee’s or self-employed partner’s contract and the terms may be amended by the Company from time to time at its sole and absolute discretion. The Company may also vary the procedure including any time limits as appropriate.
Group Company Secretary
Anglian Windows Ltd
PO Box 65
Tel: 01603 422520 (ext: 3020)
Modern Slavery Helpline
Tel: 0800 0121 700
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