About this document

The policy gives employees, workers, contractors and other business partners guidance on slavery and human trafficking and the measures taken by Netpremacy to tackle slavery and human trafficking in the business and its supply chains.

Policy Statement

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 and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or in any of our supply chains.

We are 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 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. 

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, contractors, external consultants, agency workers, seconded workers, volunteers, interns, agents, third-party representatives and business partners.

Responsibility for the policy

We all have responsibilities to ensure our colleagues are safeguarded, treated fairly and with dignity. This means that everyone needs to recognise and understand the complex issue of modern slavery and how we can ensure that it does not take place within the business or our supply chains. 

The Directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

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.

Employees are able 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 your manager.

Identifying slavery

Sometimes individuals do not understand they have been exploited and are entitled to help and support.

The following key signs are not exhaustive but could indicate that an individual may be subject to slavery or human trafficking:

• the person is not in possession of their own passport, identification or travel documents;

• the person is acting as though they are being instructed or coached by someone else;

• they allow others to speak for them when spoken to directly;

• they are dropped off and collected from work;

• the person is withdrawn or they appear frightened;

• the person does not seem to be able to contact friends or family freely;

• the person has limited social interaction or contact with people outside their immediate environment.

An individual may display a number of the trafficking indicators set out above but they may not necessarily be subject to slavery or trafficking. You will need to build up a picture of the individual’s circumstances which may indicate something is not quite right.

If you have any suspicion, you must report it.

Compliance with the policy

You must ensure that you read, understand and comply with this policy.

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.

You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. 

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at the earliest possible stage. 

If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible. 

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. 

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 your manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the Company Handbook.

Communication and awareness of this policy

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Breaches of this policy

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

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.