Modern Slavery & Human Trafficking Policy for PlumbSpark Ltd

Document Classification: PUBLIC

Date Issued: 03/05/2023

Note: This document is uncontrolled when printed.

Introduction and Policy Statement

At PlumbSpark Ltd, we recognize that modern slavery is a heinous crime and a severe violation of fundamental human rights. This vile practice can manifest in numerous forms, including slavery, servitude, forced and compulsory labor, and human trafficking. All these forms share a common characteristic: the deprivation of an individual's liberty by another to exploit them for personal or commercial gain. As a company, we have adopted a strict zero-tolerance approach to modern slavery and are fully committed to conducting all our business operations with the highest levels of ethical integrity.

We are dedicated to implementing and enforcing robust systems and controls to ensure that modern slavery does not occur within our operations or throughout our supply chains. Our commitment extends to full transparency in our business operations and our efforts to combat modern slavery, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect our contractors, suppliers, and business partners to adhere to the same high ethical standards. Our contracting processes explicitly prohibit the use of forced, compulsory, or trafficked labor, as well as any form of slavery or servitude, whether involving adults or children. We insist that our suppliers hold their own suppliers to these same rigorous standards.

This policy extends to all individuals working for or on behalf of PlumbSpark Ltd, regardless of their role or capacity. This includes employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

It is important to note that this policy is not a contractual document and may be revised at any time to reflect changes in legislation or company practices.

 

 

Responsibilities Within the Policy

The successful implementation of this policy relies on a clear delineation of responsibilities:

  1. Board of Directors: The Board holds ultimate responsibility for ensuring that this policy aligns with our legal and ethical obligations. They are also responsible for ensuring that all individuals under our control comply with the policy.

  2. Compliance Manager: The compliance manager bears the primary responsibility for the day-to-day implementation of this policy. This includes monitoring its use and effectiveness, addressing any queries related to it, and auditing internal control systems and procedures to ensure their effectiveness in countering modern slavery.

  3. Management at All Levels: Managers are tasked with ensuring that their teams understand and comply with this policy. They are responsible for providing adequate and regular training on this policy and the broader issue of modern slavery in supply chains.

  4. Employee and Stakeholder Engagement: We encourage all stakeholders to comment on this policy and suggest improvements. All comments, suggestions, and queries should be directed to the compliance manager.

Ensuring Compliance with the Policy

The effective prevention, detection, and reporting of modern slavery within any part of our business or supply chains is a shared responsibility among all individuals working for or under the control of PlumbSpark Ltd. It is imperative that everyone avoids any activities that might lead to or imply a breach of this policy.

If you suspect or believe that there is a conflict with this policy, it is critical to report this immediately to your manager, the compliance manager, or through the confidential helpline. Early reporting of concerns regarding modern slavery within our business or supply chains is strongly encouraged.

Should you suspect a breach of this policy, report it immediately to your manager or Nilesh Ladva, Director, or in accordance with our Whistleblowing Policy. We prioritize the welfare and safety of local workers and are committed to providing support and guidance to our suppliers to address coercive, abusive, and exploitative practices within their businesses and supply chains.

If you are uncertain whether an act or treatment of workers constitutes modern slavery, you should seek guidance from your manager, Nilesh Ladva, Director, or through the confidential helpline.

We are committed to fostering an environment of openness and will support any individual who raises genuine concerns in good faith under this policy, even if their concerns prove to be unfounded. We are dedicated to ensuring that no one suffers detrimental treatment as a result of reporting, in good faith, suspicions of modern slavery occurring in any part of our business or supply chains. Detrimental treatment includes dismissal, disciplinary action, threats, or any unfavorable treatment related to raising a concern. If such treatment occurs, report it to the compliance manager immediately. If unresolved, and if you are an employee, raise it formally using our Grievance Procedure, available at the BrightHR Employee Portal.

Communication and Awareness

Training on this policy, and the risks our business faces from modern slavery in its supply chains, forms an integral part of the induction process for all individuals who work for us. Regular training sessions will be conducted as necessary to reinforce understanding and awareness.

Our zero-tolerance stance on modern slavery must be communicated to all suppliers, contractors, and business partners at the beginning of our business relationships with them, and reinforced as required thereafter.

Consequences of Policy Breaches

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. PlumbSpark Ltd reserves the right to terminate its relationship with any individual or organization working on its behalf if they breach this policy.

This policy reflects PlumbSpark Ltd's unwavering commitment to preventing modern slavery and human trafficking in all its forms. All employees and associated individuals are encouraged to familiarise themselves with this policy and actively contribute to maintaining ethical business practices.

 

Authorised by: Nilesh Ladva

Position: Director

Date: 19/03/2025

Company: PlumbSpark Ltd