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Anti-Slavery Policy


Statement of Intent

In accordance with the Modern Slavery Act 2015, Highway Workforce is committed to a work environment that is free from human trafficking, forced labour and unlawful child labour (collectively “human trafficking and slavery”). It also strongly believes that it has a responsibility for promoting ethical and lawful employment practices. Accordingly, Highway Workforce will not knowingly use unlawful child labour or forced labour in any of the services it provides, nor will it accept commodities, products and/or services from suppliers that employ or utilise child labour or forced labour.

Core Policy
Human trafficking and slavery are crimes under UK and international law. These crimes exist in countries throughout the world. This policy thus defines Highway Workforce’s commitment to ensuring that human trafficking and slavery does not exist within its own business, but also provides how Highway Workforce will make efforts to eradicate the same from other businesses with whom it shall maintain a relationship (and especially from within its supply chain).

Definitions
  • Human Trafficking: the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation.
  • Forced Labour: all work or service, not voluntarily performed, that is obtained from an individual under the threat of force or penalty.
  • Harmful Child Labour: consists of the employment of children that is economically exploitative, or is likely to be hazardous to, or interfere with, the child’s education, or to be harmful to the child’s health, or physical, mental, spiritual, moral, or social development.

Requirements for Suppliers
  • Will not use forced or compulsory labour, for example any work or service that a worker performs involuntarily, under threat of penalty
  • Will ensure that the overall terms of employment are voluntary
  • Will comply with the minimum age requirements prescribed by applicable laws
  • Will compensate its workers with wages and benefits that meet or exceed the legally required minimum and will comply with overtime pay requirements
  • Will abide by applicable law concerning the maximum hours of daily labour
  • Will not engage in any practice of slavery, servitude, forced labour, compulsory labour and/or human trafficking outside the UK which would constitute an offence if that conduct took place within the UK 
  • Will ensure that any sub-contractors or suppliers from whom they source goods and/or services for incorporation in those supplied to Highway Workforce, also adhere to these requirements.

Certification
Suppliers will certify compliance with this Policy and their adherence to relevant human trafficking and slavery laws in each of the relevant countries in which they operate.
 
Audits
Upon request, Suppliers must be able to demonstrate compliance with this Policy to the reasonable satisfaction of Highway Workforce. Highway Workforce may perform periodic audits on this Policy and Suppliers are expected to fully co-operate with any such audit.

Reporting
Any breach of this Policy (including by a Supplier) can be reported (in confidence, if required) by contacting Highway Workforce’s Managing Director (in his capacity as Anti- Slavery and Human Trafficking Officer).
 
High Risk Areas
Whilst modern slavery is not restricted to any particular group of people or geographic region, some areas are at a higher risk than others. Mainland Europe and Middle Eastern regions are considered to be high risk.
 
Consequences
Highway Workforce takes any breach of this Policy extremely seriously. Suppliers who are found to have or be engaging in human trafficking and slavery or which refuse to co-operate with any audit to verify compliance with this Policy will be liable to have any supply agreement, arrangement or other contract with Highway Workforce terminated immediately, without compensation.

If a Supplier to Highway Workforce is found in violation of this policy, Highway Workforce will take prompt action which may include terminating any supply agreement, arrangement or other contract with that Supplier (as above). It shall also take such other (remedial) steps as the Anti- Slavery and Human Trafficking Officer shall determine to be necessary to address the violation and seek to prevent its reoccurrence.


Managing Director
Highway Workforce Ltd