Anti-Slavery and Human Trafficking Policy

  1. INTRODUCTION
    Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
  2. POLICY STATEMENT
    1. We have a zero-tolerance approach to modern slavery and child labour and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery and child labour is not taking place anywhere in our own business or in any of our supply chains.
    2. Our policy is to assess and address the risks of violations of anti-human trafficking and anti-modern slavery laws. We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we will always prefer to include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
    3. We ensure:
          • our values, which are embedded throughout our business, set the perimeters for how we expect our people to behave with colleagues, clients and the world at large;
          • we seek to treat everyone fairly and consistently, creating a workplace and business environment that is open, transparent and trusted;
          • our policies and procedures relating to the Modern Slavery Act align with our culture and values.
    4. 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, interns, agents, contractors, external consultants, third-party representatives and business partners.
    5. This policy does not form part of any employee’s contract of employment and may be amended at any time.
  3. RESPONSIBILITY FOR THE POLICY
    1. The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
    2. The Compliance Team, which is comprised of members of the Legal Department and the Human Resources Department, has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
    3. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
    4. You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Compliance Team at compliance@axiomsl.com.
  4. COMPLIANCE WITH THE POLICY
    1. You must ensure that you read, understand and comply with this policy.
    2. The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
    3. You must notify the Compliance Team at compliance@axiomsl.com as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. Where you prefer not to raise it with your manager or with the Compliance Team for any reason, you should contact the Whistleblowing Officer in your region.
    4. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
    5. If you believe or suspect a breach of this policy has occurred or that it may occur you must 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.
    6. 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.
    7. 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 the Whistleblowing Officer in your region.
  5. COMMUNICATION AND AWARENESS OF THIS POLICY
    1. 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.
    2. 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.
  6. BREACHES OF THIS POLICY
    1. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
    2. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.