J.D. McDougall

4 McGrath Road, Stratford,
London E15 4JP
Tel +44 (0) 20 8534 2921
Fax +44 (0) 20 8519 8423
Email mail@mcdougall.co.uk

Anti Slavery & Human Trafficking Policy

  1. 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, 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. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing effective systems and controls to ensure modern slavery is not taking place anywhere in our business.
  2. 1.2  We are also committed to ensuring there is transparency in our business and in our approach to tackling modern slavery throughout our supply chains, consistent with our commitment to 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 include specific requirements 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. 1.3  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.
  4. 1.4  This policy does not form part of any employee’s contract of employment and we may amend it at any time.

2. Responsibility for the policy

  1. 2.1  Management have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
  2. 2.2  Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate information on it and the issue of modern slavery in supply chains.
  3. 2.3  You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged.

3. Compliance with the policy

  1. 3.1  Employees must ensure that they read, understand and comply with this policy.
  2. 3.2  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. 3.3  Employees must notify their manager as soon as possible if they believe or suspect that a conflict with this policy has occurred, or may occur in the future.
  4. 3.4  Employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business or supply chains of any supplier tier at the earliest possible stage.
  5. 3.5  If any employee believes or suspects a breach of this policy has occurred or that it may occur they must notify their manager in accordance with our Whistleblowing Policy as soon as possible.
  6. 3.6  If employees 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, they should raise it with their manager.
  7. 3.7  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 business or in any of our supply chains.

4. Communication and awareness of this policy

  1. 4.1  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 training will be provided as necessary.
  2. 4.2  Our approach to modern slavery in our business and supply chains is communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

5. Breaches of this policy

  1. 5.1  Any employee who breaches this policy will face disciplinary action.
  2. 5.2  We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Policy introduced in September 2018