Anti-slavery and Human Trafficking Policy

1. Introduction 

1.1 Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Victims are coerced, deceived and forced against their free will into providing work or services. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights. 

1.2 Axscend strictly prohibit the use of modern slavery and human trafficking in our operations and supply chain. We are committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold themselves and their own suppliers to the same high standards.  


Section Page number 1. Introduction 1 2. Scope 1 3. Policy Statement  2 4. Responsibility for the policy 3 5. Reporting Modern Slavery 3 6. Breaches of this policy 3 7. Related policies 3

2. Scope

2.1 This policy applies to all persons working for Axscend Limited or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, suppliers, external consultants, third-party representatives and business partners.

2.2 This policy does not form part of any employee’s contract of employment and we may amend it at any time. 

2.3 Workers must ensure that they read, understand and comply with this policy.

3. Policy Statement 

3.1 We expect everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery: 

3.1.1 We have a zero-tolerance approach to modern slavery in our organisation or our supply chains. The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.

3.1.2 We are committed to gaining a clearer understanding of how modern slavery operates in different contexts, of who is affected and how, and of the risks of modern slavery existing within our industry.

3.1.3 We are committed to having a clear and transparent company statement, which is reviewed regularly and is communicated to our employees posted on our website, which sets out the steps taken to prevent modern slavery and trafficking and the effectiveness of those measures.

3.1.4 We are committed to training relevant employees in modern slavery, how to identify it in practice and how to respond. We are committed to ensuring that our employees understand and adhere to this Policy together with other relevant policies and our “Integrity Matters” Code of Ethics and are trained on them as appropriate. Non-compliance with those policies is a disciplinary offence. Our policies are reviewed on a regular basis, which will include our zero-tolerance to all forms of modern slavery.

3.1.5 We are committed to engaging with our industry, stakeholders, customers and suppliers to address the risk of modern slavery in our operations and supply chain. 

3.1.6 As part of our contracting processes, we will include a specific prohibition against the use of modern slavery and trafficked labour and a requirement to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.

3.1.7 Our recruitment procedures require employment and recruitment agencies and other third parties supplying workers to our organisation to comply with our Code of Conduct. Suppliers engaging workers through a third party are also required to obtain third parties’ agreement to adhere to the Code. 

3.1.8 We will do due diligence on suppliers, to monitor their compliance with our Code of Conduct. We aim to work with suppliers to remediate incidents of non-compliance and may terminate the relationship in response to gross, persistent or deliberate failures.

4. Responsibility for the policy

4.1 Each of the companies named in this policy support this policy and are committed to making available sufficient resources for its implementation and have overall responsibility for ensuring compliance.

4.2 The Human Resources department has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about this policy, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery. 

4.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy.  Relevant managers will be given adequate training and information  relating to the issue of modern slavery in supply chains.

5. Reporting Modern Slavery  

5.1 Employees must notify their manager or otherwise report a concern in accordance with the Public Interest Disclosure Policy as soon as possible if they have any reason to believe that modern slavery of any form may exist within our organisation or our supply chain, or may occur in the future or have any concerns or suspicions relating to compliance with this policy. 

5.2 If a person, other than an employee, has any reason to believe that modern slavery of any form may exist within our organisation or our supply chain, or may occur in the future or have any concerns or suspicions relating to compliance with this policy, they must notify us as soon as possible by contacting the Human Resources Department. 

5.3 We aim to encourage openness and will support anyone who raises genuine concerns under this Anti Slavery & Human Trafficking 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 their genuine 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 the Human Resources Department immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Policy. 

6. Breaches of this policy

6.1 Any employee who breaches this Anti Slavery & Human Trafficking Policy will be dealt with in accordance with the Disciplinary Policy, which could result in dismissal.

6.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

7. Related Policies

Other relevant policies include;

·        Dignity at Work Policy

·        Diversity Policy

·        Equal Opportunities Policy

·        Disciplinary Policy

·        Grievance Policy

·        Immigration and Asylum Policy

·        Public Interest Disclosure Policy (Whistle Blowing Policy)

·        “Integrity Matters” Code of Ethics