This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors’ officers, agency workers, seconded workers, volunteers, agents’ contractors and suppliers.
L.A.C. Conveyor Systems strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our company or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.
1. COMMITMENTS
Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another period with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.
We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:
(a) We have a zero-tolerance approach to modern slavery in our company and our supply chains.
(b) 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. Workers must not engage in, facilitate, or fail to report any activity that might lead to, or suggest, a breach of this policy.
(c) We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusions of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach, we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.
(d) Consistent with our risk-based approach we may require:
(i) Employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct.
(ii) Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code.
(e) As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying our audits of suppliers for their compliance with our Code of Conduct.
(f) If we find that other individuals or organisations working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.
COMPLIANCE WITH POLICY
(a) You must ensure that your read, understand and comply with this policy.
(b) You are encouraged to raise concerns about any issue
(c) You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.
(d) If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible. You should note that where appropriate, and with the welfare and safety of local workers as a priority, we may give support and guidance to our suppliers to help them address coercive or exploitative work practices in their own business and supply chains.
(e) If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager.
(f) We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this 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 in good faith their 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 your manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.
3. COMMUNICATION AND AWARENESS OF THIS POLICY
(a) Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
(b) Our zero-tolerance approach to modern slavery in our business and supply chains must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
4. BREACHES OF THIS POLICY
(a) Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
(b) We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
(c) The aims of this policy are:
(d) To encourage staff to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected.
(e) To provide staff with guidance as to how to raise those concerns.
(f) To reassure staff that they should be able to raise genuine concerns in good faith without fear of reprisals, even if they turn out to be mistaken.
