REAGENT Anti-Slavery and Human Trafficking Policy

Policy Statement:

1.1 Recognizing modern slavery as both a crime and a severe violation of fundamental human rights, it encompasses various forms such as slavery, servitude, forced labour, and human trafficking. These forms entail the deprivation of an individual’s liberty for exploitation, whether for personal or commercial gain. Our commitment is to conduct our business affairs ethically and with integrity, ensuring effective systems and controls are in place to prevent modern slavery within our business and supply chains.

1.2 We pledge transparency in our operations and in addressing modern slavery across our supply chains, in line with our obligations under the Modern Slavery Act 2015. We expect our contractors, suppliers, and other business partners to uphold the same high standards. Our contracting processes explicitly prohibit the use of forced, compulsory, or trafficked labour, as well as any form of slavery or servitude, irrespective of age, and we anticipate our suppliers to uphold these standards with their own suppliers.

1.3 This policy extends to all individuals working for us or on our behalf, including employees, directors, officers, agency workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

1.4 This policy is not part of any employee’s contractual agreement and may be subject to amendments at any time.Responsibility for the Policy.

 

2.1 The board of directors holds ultimate responsibility for ensuring compliance with legal and ethical obligations regarding this policy.

2.2 The compliance manager is tasked with the primary responsibility for implementing, monitoring, and auditing te effectiveness of this policy and associated control systems to combat modern slavery.

2.3 Management at all levels are responsible for ensuring their teams understand and adhere to this policy, providing adequate and regular training on modern slavery issues within supply chains.

2.4 Feedback on this policy and suggestions for improvement are welcomed and should be directed to the compliance manager.Compliance with the Policy

3.1 All individuals must read, understand, and comply with this policy.

3.2 The prevention, detection, and reporting of modern slavery within any aspect of our business or supply chains is the responsibility of all individuals working for us or under our control.

3.3 Prompt notification to the compliance manager is required if any conflict with this policy is suspected or believed to have occurred.

3.4 Individuals are encouraged to raise concerns about modern slavery at the earliest opportunity within our business or any tier of our supply chains.

3.5 Reporting breaches of this policy to a director is mandatory. We may offer support and guidance to suppliers to address coercive or exploitative practices in their businesses and supply chains.

3.6 Individuals unsure about potential instances of modern slavery should seek guidance from their manager or a director.

3.7 We promote openness and support those who raise concerns in good faith, ensuring no one faces detrimental treatment as a result. Any such treatment should be reported to the compliance manager.

Communication and Awareness

4.1 Training on this policy and the risks posed by modern slavery in our supply chains is part of the induction process for all employees, with regular updates provided as necessary.

4.2 Our commitment to combating modern slavery must be communicated to all suppliers, contractors, and business partners at the outset and reinforced as needed throughout our relationships.

Breaches of the Policy

5.1 Employees breaching this policy will face disciplinary action, including dismissal for misconduct or gross misconduct.

5.2 We reserve the right to terminate relationships with individuals or organisations breaching this policy.

Queries, Amendments & Review

Any queries should be directed to a Director of ReAgent Recruitment Ltd. Amendments will be communicated through revisions to this document. This policy will be periodically reviewed.

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