Modern Slavery & Human Trafficking Policy

Introduction

Our Company is committed to making sure there is transparency within our own business and in our approach to tackling Modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015 and other local laws. Our moral and legal obligations are for the safety of all our colleagues, suppliers, contractors and customers. 

We take the responsibility of modern slavery and human trafficking very seriously. It is a crime and violation of human rights, which takes various forms such as slavery, servitude, forced and compulsory labor and human trafficking. All of which have in common the deprivation of another person’s liberty by another, in order to exploit them for personal or commercial gain. 

We have a zero-tolerance approach to modern slavery and we are committed to acting ethically with integrity in all our business dealings and relationships and are committed to implementing and enforcing effective systems and controls to make sure modern slavery is not taking place anywhere within our business or in any of our supply chains. 

We ensure that all our colleagues are not exploited and are paid at or above the National Minimum Wage or the National Living Wage, with relevant training and within a safe working environment. All colleagues are given the company handbook on commencement of their contract. 

We work with our supply chains to ensure they also take the responsibility to protect their colleagues and contractors to help ensure no one within their chain is being exploited to help combat modern slavery. 

We want all our colleagues to have a positive experience working with us. We do not want our colleagues to feel harassed, discriminated against, bullied or coerced. At no time should they be asked for gifts or money for working with us. 

Definition of Slavery and Servitude 

Slavery, in accordance with the 1926 Slavery Convention, is the status or condition of a person over whom all or powers attaching to the right of ownership are exercised. Since legal ownership of a person is not possible, the key element of slavery is the behavior on the part of the offender as he/she did own the person, which deprives the victim of their freedom. 

Servitude is the obligation to provide services that are imposed using coercion. This includes the obligation to provide services that are imposed by the use of coercion, the obligation for a serf to live on another person’s property and the impossibility of changing his or her condition. 

Definition of Human Trafficking 

An offense of human trafficking requires that a person arranges or facilitates the travel of another person with a view to that person being exploited. The offense can be committed even when the victim consents to the travel. This reflects the fact that the victim may be deceived by the promise of a better life or a job or maybe a child who is influenced to travel by an adult. In addition, the exploitation of the potential victim does not need to have taken place for the offense to be committed. It means that the arranging or facilitating the movement of the individual was with a view to exploiting them for sexual or non-sexual exploitation. 

Whistleblowing Policy 

Our Company encourages all our colleagues, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Colleagues who have concerns should raise these with their Line Manager in the first instance or can send an anonymous email to people@venatus.com. 

Colleague Code of Conduct 

The Company's code outlines the actions and behavior expected of all colleagues when representing the Company. The Company strives to maintain the highest standards of colleague conduct and ethical behavior and when managing its supply chain. 

Supplier/Procurement Code of Conduct 

Our Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labor. The Company works with suppliers to ensure that they meet the standards of the code and improve their workers working conditions. However, serious violations of the Company's supplier code of conduct (Appendix 1) will lead to the termination of the business relationship. 

Recruitment Agency Policy 

Our Company only uses specified, reputable recruitment consultants to source labor and always verifies the practices of any new agency it is using before accepting workers from that agency, who undertake the same training as internal recruited colleagues. 

Due Diligence 

Internally, we have several processes in place to verify the identity of our colleagues to make sure we know exactly who is part of our teams. All our colleagues undergo identity and right to work checks before they are offered a contract with us. This is audited as part of our internal audit process. We also carry out reference checks, as appropriate qualifications. 

Equality and Harassment 

It’s against our Company policy for any colleague (or third party) to harass or bully another colleague, relative or customer in any way. We have various ways of dealing with alleged instances of harassment or bullying, as outlined in our Company Handbook. We’re also committed to giving people equal opportunities and our policies are designed so that all colleagues are treated fair and equally. We ensure this happens by applying our Equal Opportunities at all stages of our recruitment and selection process and we avoid any unlawful discrimination in all aspects of employment. 

Communication 

Our Company has a confidential whistleblowing option for colleagues to report any concerns they have in respect of wrongdoing within our Company. 

This policy will be communicated to all new colleagues within their induction period as well as display posters for our colleagues to see on a regular basis. 

Compliance with the Policy 

You must make sure that you read, understand and comply with this policy. 

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

We encourage everyone to raise concerns about any issue or suspicion in any parts of our business or supply chains of any suppliers. 

If there has been a breach or conflict of this policy or you are unsure whether a particular act, the treatment of colleagues more generally, or their working conditions within any tier of our supply chains, constitutes any form of modern slavery or human trafficking, please contact your line manager in the first instance, who will contact our Chief Operating Officer. Other support lines are as follows: 

Hope for Justice helpline 

UK: (+44) 08000 121 700 

USA: (+1) 615-356-0946 

AUS: (+61) 1300 899 184 

If you believe anyone to be in immediate danger, call local emergency services and communicate with your line manager. 

Breaches of the Policy 

Any colleague found in breach of this policy will be subject to disciplinary action for gross misconduct under the company’s disciplinary policy, which may include disciplinary action up to and including dismissal. 

We may terminate our relationship with other individuals, organizations and suppliers if they are found in breach of this policy. 

Amendments to the Policy 

This policy does not form part of the colleagues Terms of Employment and may vary from time to time. As a minimum, the statement may change annually to reflect actions taken within the financial year. 

Board Member Approval 

This Statement has been approved by all the Board Members and reviewed by the Company’s Chief Operating Officer, Head of People and Chief Executive Officer, who will review and update the statement annually.