Modern Slavery and human trafficking policy

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.

The Corpex Group 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 organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards. We adopt the ETI Base Code 9 Principles as our Code of Conduct.

 

Modern Slavery and Human Trafficking

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 person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

 

Commitments

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:

 

• We have a zero-tolerance approach to modern slavery in our organisation and 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.
• The Corpex Group recognises that modern slavery and human trafficking could be potential risks to our business. We have strict policies and procedures in place to ensure the consistent monitoring of our candidates for the signs of human trafficking and labour exploitation. These checks are paramount to allowing us to identify exploitation at the earliest stage.
• When a potential candidate chooses to register with The Corpex Group the checks begin. These continue throughout the candidate’s employment. At the time of registration, the identification and ‘right to work’ checks are conducted. This ensures that the candidate has control of their own documentation and that their job expectations are managed effectively. All interviews are completed face-to-face with the individual confidentially to make sure that they have freely chosen to attend. In addition, throughout the registration and interview process, all registration documents are checked and verified as being the applicant’s own information.

All our sites and branches have literature available for candidates which informs them of contact details for all the relevant authorities who can assist them if required.

• We are confident that we have the right checks in place to minimise the risk of human trafficking and labour exploitation taking place within our company. We strive to continuously improve systems, policies and procedures to protect workers who may be vulnerable..
• We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
• We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion 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.

 

Consistent with our risk-based approach we may require:

• Third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct
• Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code

• As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.
• 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