Policy statement

This statement is made pursuant to S.54 of the Modern Slavery Act 2015 and sets out the steps that Stamford Products Ltd has taken and is continuing to take to ensure that modern slavery of human trafficking is not taking part within our business or supply chain. 

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. 

We have a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against all form of modern slavery taking place within the business or supply chain. We will work towards ensuring all of our key supplier contracts contain an anti-slavery clause. This clause will contractually prohibit suppliers and their employees from engaging in slavery or human trafficking.

Aims of this policy 

We endeavour to ensure that modern slavery is not evident in any aspect of our business dealings. 

This policy will be used to underpin and inform any statement on slavery and human trafficking that we are required to produce further to the transparency in supply chain requirements of S.54 of the Modern Slavery Act 2015. 

This policy applies to all persons working for us or on our behalf in any capacity, including employees, directors, officers, agency workers, contractors, consultants, apprentices, third-party representatives, and business partners. 

We expect all who have or seek a business relationship with the company to familiarise themselves with this policy and to act at all times in a way that is consistent with its values. This will be via our public statement on our website. 

The following key principles apply to our business and suppliers: 

1. Child labour must not be used, and we and our suppliers must not benefit from child labour. 
2. Any form of forced or compulsory labour must not be used and we and our suppliers must not benefit from forced or compulsory labour. Workers must be free to leave employment or work after reasonable notice. 
3. Passports or other original forms of identification should not be taken from workers. 
4. All forms of debt bondage are prohibited. Workers should not be subject to contracts that tie them into repaying loan, accommodation, or some other costs that they have little opportunity to repay. 
5. Compensation and benefits must comply with fundamental principles relating to minimum wages, overtime hours and legally mandated benefits. 
6. The formation of trade unions and powers of collective bargaining should be respected in keeping with the applicable legislation of the jurisdiction in question. 
7. Workers should have safe and healthy working conditions that meet or exceed applicable standards for occupational safety and health and be free from any threat of violence, harassment, and intimidation.

How we seek to embed our anti-slavery policy in practice

To underpin our policy commitments, we are in the process of implementing the following measures over the course of the financial year. 

• The Policy will be available to all staff with guidance to raise any matters in connection with it to their line manager by way of the Company Grievance Procedure or Whistleblowing. 
• To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and in our business, our key purchasing staff will undertake external training. This will help them to understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain. 
• All Company Policies to be issued to employees, copies will be made available on the Company intranet and noticeboards across the site. 
• The Policy will be incorporated into the Employee Handbook so that it is brought to the new employees’ attention when they start working for Stamford Products Ltd. 
• All new suppliers that are looking to work with Stamford Products Ltd as part of the due diligence process will be provided with the Modern Slavery Policy and we will request copies of their Modern Slavery policy. 
• As part of our process to identify and mitigate risk, we will review arrangements with existing suppliers to ensure continued compliance with this policy. 
• Establish Key Performance Indicators to establish the effectiveness of the steps being taken to ensure that slavery and/or human trafficking is not taking place within our business or supply chain.

Incident reporting

We encourage both suppliers and our staff to report any incidents or suspicions of modern slavery through their respective line management structure and in turn to a Director. All staff will be made aware of our Whistleblowing procedure contained within the Employee Handbook which allows our employees to report any concerns confidentially. The purpose of this procedure is to enable Stamford Products Ltd to thoroughly investigate allegations of any wrongdoing raised by staff within the Company without fear of reprisal. 

Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct and may lead to dismissal further to our disciplinary procedure. 

We reserve the right to terminate our relationship with other individuals and organisations if they breach this policy or is found guilty of committing an offense covered by the Modern Slavery Act 2015. 

Everybody to whom this policy applies will be expected to co-operate to the fullest extent possible in any investigation into suspected breaches of this policy or any related process or procedure.

Responsibility for this policy

The Board of Directors has overall responsibility for this policy and in ensuring that the Company complies with all its legal and ethical obligations. 

Stamford Products Ltd will continue to develop its commitment to combat modern slavery and human trafficking by reviewing the policy annually. 

Download - SPL-POL-015