Modern Slavery Policy
Effective Date: 22nd February, 2024
Last Updated: 14th November, 2024
Modern Slavery Policy
Overview and How We Define Modern Slavery
1.1 Slavery, child labour, and human trafficking are serious crimes and a violation of fundamental human rights. There are various forms of this ‘Modern Slavery’ which deprives victims of their liberty and usually involves financial exploitation.
1.2 At TreadTracker, we conduct our business fairly, ethically, and with respect to fundamental human rights. We are fully committed to the prevention of all forms of slavery, forced labour or servitude, child labour, and human trafficking, both in our business and in our supply chains. We will not tolerate it.
1.3 This policy does not form part of your contract of employment, and we reserve the right to amend this policy at any time.
1.4 You are required to read and comply with this policy if you work for, or on behalf of the Company in any capacity including as: an employee, director, officer, worker, consultant, volunteer, supplier, or service provider.
1.5 The Company’s Anti-Slavery Officer, Stephen Richardson (‘ASO’), is responsible for this policy.
1.6 Failure to comply with this policy may result in disciplinary action, including dismissal, or termination of the contract between you and the Company. It could also involve other legal steps being taken against you.
Preventing Slavery and Human-Trafficking in Our Business
2.1 The Company makes appropriate checks on all employees, recruitment agencies, and suppliers, to know who is working for, or on behalf of us.
2.2 The Company provides every employee with a written contract of employment. We pay every employee in accordance with the law. We comply with our legal obligations to ensure the health and safety of all of our employees and workers, including in relation to working hours, rest breaks, and holidays.
2.3 All employees are required to sign a copy of this policy to show they have read and understood it. All managers are provided with training on this policy.
If You Are One of Our Suppliers
3.1 If you supply the Company with goods or services, you must assess your business and supply chains and confirm to our ASO that you comply with your legal obligations in relation to Modern Slavery, and are committed to ensuring there is no slavery, forced labour or servitude, child labour, or human trafficking taking place in your business or any of your supply chains. You must also provide a copy of your anti-slavery policy.
3.2 If you breach this policy, or are found to have slavery or human trafficking in your business or knowingly in your supply chain, the Company may terminate the contract with you and pursue its legal remedies against you.
If You Are an Employee or Worker Providing Services for Us
4.1 You must immediately report any suspicions of Modern Slavery or human trafficking in our business or supply chains to our ASO. Our ASO will investigate and report to our Board of Directors, within a reasonable time, on actions which may require to be taken.
4.2 You will not suffer any detrimental treatment as a result of reporting any genuine concerns, raised in good faith, under this policy. This applies even if, after investigation, they are found to be mistaken. If you believe that you have suffered any such treatment, you should immediately inform our ASO, and if you are an employee, refer to our Grievance and Whistleblowing Policies.
Slavery & Human Trafficking Statement
What This Policy Covers
Slavery and Human Trafficking remain a hidden blight on our global society. We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain.
Our Commitment
The Company is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We are committed to acting ethically and with integrity in all our business relationships and taking reasonable steps to ensure slavery and human trafficking are not taking place in any business or organisation that has any sort of a business relationship with our Company.
Due Diligence Processes for Slavery and Human Trafficking
The Company has zero tolerance for slavery and human trafficking. We expect all those in our supply chain and contractors to comply with our values. As part of our initiative to identify and mitigate risk, the Company has in place systems to encourage the reporting of concerns and the protection of whistleblowers.
Our supply chain providers are always with a UK provider and we expect these entities to have suitable anti-slavery and human trafficking policies and processes.
Training
The management team is responsible for compliance within their respective departments and in their supplier relationships and have been trained accordingly. All employees receive an induction into the business where our policies, procedures, and expectations are outlined.
Our Effectiveness in Combating Slavery and Human Trafficking
The Company uses the following key performance indicators to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
- Use of labour monitoring, right-to-work documentation, and payroll audits
- We maintain a level of communication and personal contact with the next link in the supply chain to ensure their understanding of, and compliance with, our expectations
- We regularly review supply chain policies, codes of conduct, and our working practices to show commitment
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes the Company’s slavery and human trafficking statement.
Reporting Suspicions of Slavery
Employees can report any suspicions of slavery either through the Company’s Public Interest Disclosure (Whistleblowing) policy or externally to the Modern Slavery Helpline. Details are set out below:
https://modernslavery.co.uk/contact.html
0800 0121 700
TreadTracker Ltd, PO Box 1458 Thornton Cleveleys, FY1 9TL
Registered in England No. 05312582.
Signed: Steve Richardson
Managing Director
22/02/2024 Review Date: 21/02/2025