Modern Slavery In Supply Chain Policy


As part of our broader approach to protecting and promoting human rights in  our supply chain, we neither support nor condone any form of modern slavery.  

Modern Slavery is a term developed by the UK Government to describe acts of  slavery, servitude, forced or compulsory labour and human trafficking. Full definitions  of these terms can be found in the UK Government’s ‘Transparency in Supply Chains  etc. a practical guide’.1 

The International Labour Organization (ILO) estimates that there are 20.9 million  persons in forced labour globally, including 14.2 million in the private economy2 and  the 2016 Global Slavery Index estimates that there are 45.8 million in modern slavery worldwide3.  

Given the prevalence of modern slavery and the complexity of today’s supply chains,  we recognise our responsibility to identify and tackle the potential for modern slavery  within our own supply chain. 

We undertake to do the following: 

  • Communicate our modern slavery in supply chain policy, including the following  supplier standards, to our suppliers 
  • Communicate our procurement principles to our suppliers 
  • Expect our suppliers to require the same requirements of their suppliers  Provide guidance and support to suppliers, where required 
  • Undertake ongoing due diligence to identify the areas of highest risk and  identify ways in which to mitigate the risks 
  • Via audit, supplier visits and dialogue, identify areas for improvement Provide training for our staff to raise awareness and develop capability Implement the Employer Pays Principle 
  • Undertake appropriate investigations if modern slavery is reported or suspected  in our supply chain 
  • Ensure that, where it is found that we have caused or contributed to modern  slavery, we provide or contribute to appropriate remediation 
  • Publish our supplier audit results  
  • Report on progress and identify our next steps for continuous improvement Publish an annual modern slavery statement. 

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Supplier Standards 

These standards are drawn from the ILO’s Declaration on Fundamental Principles and  Rights at Work and the Tripartite Declaration of Principles concerning Multinational  Enterprises and Social Policy, the UN Protocol to Prevent, Suppress and Punish  Trafficking in Persons, Especially Women and Children, and the UN Guiding Principles  on Business and Human Rights.  

These standards apply to all suppliers contracted to provide goods and services and  their labour providers.  

Prison Labour  

  1. Work or service can only be required from prisoners who have been convicted  in a court of law. Such work or service must be carried out under the supervision  and control of a public authority, for example the prison administration of a  State-run facility. Prison workers must not be hired to or placed at the disposal  of private individuals, companies or associations. Compulsory work or service  by prisoners is not allowed for private undertakings either inside or outside the  prison, or within privately administered prisons. 
  2. Work or service performed by prisoners in a private undertaking must be  voluntary. Prison workers must give their consent to working for a private  employer without being subject to a threat or penalty, including the loss of rights  or privileges within the prison. 
  3. Conditions for prisoners who have consented to work within private  undertakings should approximate the conditions enjoyed by free workers.  Prison workers should have access to wage levels, social security benefits and  occupational safety and health standards that approximate a free labour  relationship. Reasonable differences in wage levels are acceptable on the basis  of deductions made for board and lodging and for contributions to victim  compensation schemes. 


  1. Freedom of Employment: All workers shall have the right to enter into  employment voluntarily and freely, without the threat of a penalty. 
  2. Termination of Employment: Workers shall have the freedom to terminate  employment of indefinite or long duration by means of notice of reasonable  length (in accordance with national law or collective agreement) at any time  without penalty. Workers on contracts of fixed duration shall not be required to  serve beyond the expiry of their contract. Employers shall not use means to  restrict a worker’s ability to terminate employment, for example by requiring  deposits, withholding employee documentation, threats or use of violence,  imposing financial penalties or requiring payment of recruitment fees. 
  3. Threat of Violence, Harassment & Intimidation: Employers shall not exact work  or service from any person under the menace of any penalty. This includes the  use or threat of physical or sexual violence or harassment.

Coercion in Wage Payment, including Debt Bondage and Bonded Labour 

  1. Wages shall be paid regularly, and methods of payment are prohibited that  deprive workers of the genuine possibility of terminating employment. Wage  payments shall not be delayed or deferred such that wage arrears accumulate. 
  2. Wages shall be paid directly to the worker and should be paid in legal tender,  or by cheque or money order where permitted by law, collective agreement or  with the consent of the worker. Payment in the form of vouchers, coupons or  promissory notes is prohibited. 
  3. Payments “in kind” in the form of goods or services shall not be used to create  a state of dependency of the worker on the employer. “In-kind” payments should  only be partial to ensure that the worker is not totally deprived of cash  remuneration and are permitted only if authorised by national law, regulation or  collective agreement. 

10.Workers who earn wages calculated on a performance-related or piece-rate  basis shall not earn less than the legally mandated minimum wage. 

11.Workers shall not be held in debt bondage or forced to work for an employer in  order to pay off an actually incurred or inherited debt. 

12.Deception in wage payment, wage advances and loans to employees shall not  be used as a means to bind workers to employment. Advances and loans, and  deductions from wages made for their repayment, shall not exceed the limits  prescribed by national law. Workers shall be duly informed of the terms and  conditions surrounding the granting and repayment of advances and loans. 

13.No deductions from wages shall be made with the aim of indebting a worker  and binding him or her to employment, and measures should be taken to limit  wage deductions to prevent such conditions. Workers shall be informed of the  conditions and extent of wage deductions, and only deductions authorised by  national law, collective agreement or arbitration award shall be made. 

14.Workers shall not be compelled to make use of stores or services operated in  connection with an undertaking. Where access to other stores or services is not  possible, employers shall ensure that goods or services are sold or provided at  fair and reasonable prices, without the aim of indebting or otherwise coercing  the workers concerned. 

Disciplinary Measures 

15.Disciplinary measures should not include sanctions that result in an obligation  to work. 

16.Compulsory labour shall not be used to discipline workers or as punishment for  participation in a strike. 

Compulsory Overtime 

17.Workers shall not be forced to work overtime above the limits permitted in  national law and collective agreements under the menace of a penalty, for  example the threat of dismissal.

18.Work or service outside normal daily working hours shall not be imposed by  exploiting a worker’s vulnerability under the menace of a penalty. For example,  employers shall not set performance targets that result in an obligation to work  beyond normal working hours because of the worker’s need to be able to earn  the minimum wage. 

19.Freedom of Movement: Coercion shall not be used to physically confine or  imprison workers to the workplace or related premises, for example  employer-operated residences. Mandatory residence in employer-operated  residences shall not be made a condition of employment. 

20.Conditions relating to Skills Development & Vocational Training: Training  opportunities provided to employees shall be undertaken voluntarily. Employers  who provide such opportunities shall not unreasonably impose work or service  as a means of recovering the costs associated with them. 

Human Trafficking & Forced Labour  

Migration for Employment 

21.Migrant workers, irrespective of their legal status, shall be treated fairly, and  measures shall be taken to prevent abusive conditions and fraudulent practices  that may lead to coercion and trafficking for labour exploitation. 

22.Migrant workers shall benefit from conditions of work no less favourable than  those available to local workers and shall have the right to enter into and  terminate employment (with reasonable notice in accordance with national law  or collective agreement) voluntarily and freely, without the threat of a penalty. 

23.Employers shall not threaten irregular migrant workers or their family members  with denunciation to the authorities or otherwise coerce such workers into  taking up or maintaining employment. 

24.Recruitment of Migrant Workers: No fee or cost for recruitment shall be charged  directly or indirectly, in whole or in part, to the worker. If an exception is made,  it should be in the interest of the workers concerned, and after consulting the  most representative organisations of employers and workers. All costs related  to recruitment should be disclosed to the workers. 

Document Retention 

25.Practices such as confiscating or withholding worker identity documents or  other valuable items (e.g. work permits and travel documentation) are  prohibited. 

26.However, if requested by workers, employers may provide secure storage for  such documents. Workers must then be free to access them at any time upon  request. 

27.Employers shall not retain personal documents for the purpose of binding  workers to employment.

Private Employment Agencies 

28.Within their sphere of influence and to the best of their ability, employers who  engage private employment agencies to recruit members of their workforce  shall take measures to: 

29.Ensure that such agencies do not engage in fraudulent practices that place  workers at risk of forced labour and trafficking for labour exploitation. 

30.Prevent the abuse of workers contracted by such agencies, for example by  ensuring that such workers receive adequate protection in relation to  wage-related matters, working hours, overtime and other working conditions. 

31.To the greatest extent possible, ensure that fees or costs related to recruitment  are not borne by workers but by the contracting company. 

32.Use only those recruitment agencies that are licensed or certified by the  competent authority. 

Contracts of Employment 

33.Employers shall provide written contracts of employment in a language that  migrant workers can easily understand and that clearly indicate their rights and  responsibilities with regard to payment of wages, working hours, valid grounds  for termination and other issues related to preventing forced labour. 

Worst Forms of Child Labour  

34.Employers shall take immediate and effective measures to prevent and  eliminate the engagement of children in the worst forms of child labour,  including debt bondage, serfdom, forced or compulsory labour and all forms of  slavery and practices similar to slavery, such as the sale and trafficking of  children. 

35.Employers who engage private employment agencies shall ensure that such  agencies do not engage children in the worst forms of child labour as indicated  above.