Modern Day Slavery Policy

Modern Day Slavery Policy

1. POLICY STATEMENT

1.1 This policy sets out the Company’s zero-tolerance approach to modern slavery. The Company is committed to acting ethically and with integrity in all its business dealings and relationships. The Company implements and enforces effective systems, to control and ensure modern slavery is not taking place anywhere in its UK business operations, or in any of the Companies supply chain. 

1.2 Modern slavery is a crime and a violation of fundamental human rights. The Company recognises this 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. 

1.3 The Company is committed to ensuring there is transparency in its business and in its approach to tackling modern slavery throughout its supply chains, consistent with its disclosure obligations under the Modern Slavery Act 2015. The Company expects the same high standards from all of its suppliers, contractors and other third parties. As part of the Company’s contracting processes, it expects that its suppliers will hold their own suppliers to the same standards set out in this policy. 

1.4 The board of directors have overall responsibility for ensuring this policy complies with the company’s legal and ethical obligations and that all those staff and third parties under its control comply with it. 

1.5 This policy does not form part of any employee’s contract of employment and the company may amend it at any time.

2. WHO DOES THIS POLICY APPLY TO?

2.1 This policy applies to all persons working for Oliver Hydcovalves Ltd, Oliver Valves Ltd, Oliver Valvetek Ltd, Oliver Twinsafe Ltd, Oliver Valves India Pvt Ltd (the “Company”), or on its behalf in any capacity- including employees at all levels, directors and officers (“staff”). This also applies to third parties, including; agency workers, customers, suppliers seconded workers, volunteers, interns, agents, contractors, external consultants (“third parties”).

3.    SCOPE AND PURPOSE OF THE POLICY

3.1 This policy describes how the Company will prevent, detect and report modern slavery in any part of its business or supply chains. 

3.2 The Company aims 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. The Company is 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 the business- or in any of the Company’s supply chains. Detrimental treatment includes; dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If any staff believe they have suffered any such treatment, the individual should inform either their manager, or the HR department immediately. If the matter is not remedied, an employee should raise it formally in accordance with the local Grievance Procedure, which is published on the local intranet. 

4. COMPLIANCE WITH THE POLICY 

4.1 All staff and third parties must comply with this policy and are required to avoid any activity that might lead to, or suggest, a breach of this policy. 

4.2 All staff and third parties are required to raise any concerns about any issue- or suspicion of modern slavery- in any parts of the Company’s business or supply chains, of any supplier tier at the earliest possible stage. 

4.3 If any staff believe or suspect a breach of policy has occurred, or that it may occur, the individual must notify either their manager, or the UK Legal Department, or report it in accordance with the procedure set out in the Company’s Code of Business Conduct and Ethics as soon as possible. Third parties should notify a senior Company point of contact. 

4.4 If staff or third parties are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of the Company’s supply chains constitutes any of the various form of modern slavery, this should be raised as set out in paragraph 4.3. 

4.5 All managers are responsible for ensuring that this policy and the Company’s zero tolerance approach to modern slavery, is communicated to all employees. They are also responsible for ensuring those individuals reporting to them, understand and comply with this policy and are given adequate and regular training, as applicable on the policy and the issue of modern slavery in supply chains. 

4.6 Management have 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. 

4.7 All managers who are responsible for procurement of goods and/or services, must ensure that this policy and the Company’s zero-tolerance approach to modern slavery is communicated to all third parties during the procurement process and/or at the outset of each business relationship. 

4.8 Managers are responsible for ensuring that all relevant existing third party contracts include obligation to comply with the Modern Slavery Act and new third party contracts contain applicable prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. Managers may utilise the ‘Template Letter’ in ‘Schedule 1’ for amending existing contracts and ‘Template Contract Clauses’ in ‘Schedule 2’ for inclusion in all new contracts entered in to, following the launch of this policy. 

5. INVESTIGATIONS & DISCIPLINARY ACTION

5.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. 

5.2 The Company may terminate its relationship with other third parties if they breach this policy. 

6. REVIEW OF THE POLICY

6.1 The HR Department has overall responsibility for reviewing this policy.