1. Policy Statement
1.1 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. (“modern slavery”), all of which include the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
1.2 Xbite Ltd (the “company”) has a zero-tolerance approach to modern slavery within its business and supply chains.
1.3 This policy applies to all persons:
1.4 The Company is committed to:
1.5 We expect the same high standards from all of our suppliers. As part of our contracting process, we include specific prohibitions against modern slavery, and we expect that our suppliers will hold their own to the same high standards.
2. Identifying Modern Slavery
2.1 Modern slavery may be found in:
2.2 There is no typical victim of modern slavery, and some victims do not understand they have been exploited and are entitled to help and support. However, the following key signs could indicate that someone may be a victim of modern slavery or human trafficking:
The above list is not exhaustive. A person may display a number of the indicators set out above, but they may not necessarily be a victim of slavery or trafficking.
3. Responsibility For This Policy And Compliance
3.1 The Management has overall responsibility for ensuring this policy complies with the Company’s legal and ethical obligations.
3.2 The company’s HR Department has a primary responsibility for implementing this policy, and dealing with any queries about it.
3.3 All company staff must comply with this policy.
3.4 All suppliers must comply with this policy.
4. Reporting Modern Slavery
4.1 Company staff and suppliers must report any incident or suspicion of modern slavery at the earliest possible stage to:
Publication of this policy
5.1 This policy is now available to company staff in the company staff handbook.
5.2 This policy is available to suppliers on the company website.
6 Breaches of this policy
6.1 Any company staff member who breaches this policy may face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
6.2 The relevant member of the company may terminate its relationship with a Supplier if it is in breach of this policy.
7. Policy Review
7.1 The Management team, in conjunction with Human Resources, is responsible for reviewing this policy as necessary to ensure that it meets legal and ethical requirements and reflects best practice.
7.2 Company staff members are invited to comment on this policy and suggest ways in which it might be improved by emailing feedback to the Management team.
Approved by the Board of Directors
Date of Approval: 28/03/19
Signed by: Nick Whitehead (Managing Director)